Farnsworth v. State

Decision Date18 November 2022
Docket Number20-0786
PartiesJAMES FARNSWORTH II, Appellant, v. STATE OF IOWA, Appellee.
CourtIowa Supreme Court

Submitted September 14, 2022

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Cerro Gordo County Christopher C. Foy, Judge.

Both the defendant and the State seek further review of a court of appeals decision in a postconviction-relief proceeding that declined to disturb the defendant's second-degree murder conviction but ordered the return of a previously-forfeited $50,000 cash bond.

Philip B. Mears of Mears Law Office, Iowa City, for appellant.

Thomas J. Miller, Attorney General, and Kyle Hanson, Assistant Attorney General, for appellee.

Mansfield, J., delivered the opinion of the court, in which all participating justices joined. May, J., took no part in the consideration or decision of the case.


I. Introduction.

A decade ago, a melee between two young men resulted in the death of one of them. The defendant, who had pulled a knife and fatally stabbed the decedent, was charged with first-degree murder; he claimed self-defense. To obtain pretrial release, the defendant's family had to post a $200,000 cash bond, with $50,000 subject to the condition that it would be forfeited for restitution purposes if the defendant were convicted. Following a jury trial, the defendant was found guilty of the lesser included offense of second-degree murder. The $50,000 was forfeited to pay victim restitution.

The defendant applied for postconviction relief, raising several claims of ineffective assistance of counsel. The district court denied the application. The court of appeals affirmed on the issues relating to the defendant's conviction but reversed as to the bond forfeiture order. It found that the defendant's counsel had been ineffective in failing to challenge what it viewed as an unlawful bond forfeiture order. The court of appeals remanded for return of the $50,000 to the defendant.

We granted both parties' applications for further review. In our discretion, we let the court of appeals decision stand as the final appellate decision on all issues relating to the defendant's conviction. We reverse the court of appeals decision on the bond forfeiture issue. While we do not approve of the forfeiture order that was entered in this case, we hold that postconviction relief is not a way to overturn that order. Generally, bond forfeiture orders are civil matters separate from the actual criminal proceeding. And to the extent that the forfeiture order here could be deemed part of the defendant's sentence, it nonetheless "relat[es] to restitution" and thus cannot be the basis for postconviction relief. See Iowa Code § 822.2(1)(g) (2015).

II. Facts and Procedural History.

In 2014, the court of appeals affirmed James Farnsworth's second-degree murder conviction, summarizing the relevant facts as follows:

Several witnesses to the details of this incident testified, each relating slightly different facts depending on their proximity to certain actions. None, however, contradicted another. Based on this testimony, the jury could have found the following facts. On April 13, 2012, Farnsworth, his girlfriend, Victoria Miller, and several others were at the apartment of Echo Dority. The group then decided to go to a local bar. At the bar, Miller received a text of a smiley face from her ex-boyfriend, Ian Decker, who is also the father of her child. Farnsworth and Miller argued, and Farnsworth slapped Miller. Miller then told Farnsworth she was "done with him" and that he should leave. With the encouragement of others in the group, Farnsworth left.
Not long after that, the group decided to go back to Dority's apartment. Farnsworth was waiting around the corner from the bar. Miller ignored Farnsworth and others told him to leave. Undeterred, Farnsworth followed the group, which continued to largely ignore his presence. When Farnsworth approached Miller, Dority kicked Farnsworth in the crotch, causing him to fall to the ground. Farnsworth got up and ran to Dority's apartment, arriving ahead of the group.
Dority did not allow Farnsworth to enter her apartment. In an effort to talk with Miller, Farnsworth sent her numerous text messages. Miller replied, telling him to leave and that "[e]veryone wants to beat the f * * * out of you." Farnsworth threatened to kill himself and walked away from the door and out of sight of those in the apartment.
Dority and Miller went outside the apartment to wait for Decker, whom Dority had invited. After Decker's arrival, Farnsworth came from around the corner and made a request to speak with Miller, which she refused. Miller and Decker told Farnsworth to leave, so he got in his car and drove quickly away. However, a few minutes later, Farnsworth "came barreling back down the street" as other guests, Alyssa Fullerton and Derek Wentworth, were leaving the apartment. Miller and Wentworth told Farnsworth to leave. Farnsworth approached Miller, and Wentworth stepped between the two. After Miller informed Farnsworth she did not want to speak with him, Farnsworth stated: "If Ian [Decker] tries anything, I'm going to f * * * * * * stab him."
Decker was standing around the corner of the apartment building. Upon hearing Miller and Farnsworth arguing, Decker appeared to be very angry. He walked around the corner and began fighting with Farnsworth. It was not disputed that Decker threw the first punch. Miller tried to warn Decker by yelling, "[S]top, [Decker], he has a knife." The two continued fighting and grappled on the ground but both got back up. At one point, Decker was hunched over Farnsworth, but Farnsworth was able to throw Decker off of him. When Decker stood up, he lifted his shirt to reveal blood streaming down his chest and onto the sidewalk. Decker collapsed; Miller and Dority applied pressure to his chest wound. Farnsworth stood there briefly, then got in his car and sped away. It was later revealed Decker had been stabbed once in the ribs, once in the thigh, and had a cutting wound on his left forearm. Although police and paramedics quickly arrived, Decker died at the scene from the stab wound in his side, which had pierced his heart.
Police stopped Farnsworth shortly after he drove away. Farnsworth was cooperative and informed police the knife was in his center console. When asked what happened, Farnsworth replied Decker had punched him four or five times, prompting Farnsworth to pull the knife from his pocket and "[fling] it around." Although Farnsworth had some visible injuries, he refused medical treatment and was transported to the police station. Farnsworth later complained about being dizzy, and was then taken to the hospital. A neurological exam revealed the absence of a head injury, and though the doctor thought perhaps Farnsworth's nose was broken, Farnsworth refused to have X-rays taken and declined further treatment.

State v. Farnsworth, 2014 WL 2884732, at *1-2 (Iowa Ct. App. June 25, 2014) (alterations in original) (footnote omitted).

Soon after the above-described events, Farnsworth was arrested by the Mason City police and charged with first-degree murder. He was initially held in jail on a $100,000 cash bond. Farnsworth applied for bond review, and a hearing took place. After that, the bond was increased to $200,000 cash, but with the proviso that $150,000 of the cash could be posted by a surety while $50,000 had to be deposited in the defendant's name. This requirement was intended to allow the $50,000 to be applied immediately to restitution if the defendant were convicted.

A month later, Farnsworth again sought bond review. He asked for permission to post a surety bond instead of cash for the $150,000 that did not have to be in his name. The State countered that Farnsworth should be required to post an increased sum of $100,000 in cash bond under his own name. The district court adopted neither suggestion and left the existing bail conditions in place.

To meet those conditions, a $50,000 cash bond was posted in the defendant's name, while a bail bonding company posted the remaining $150,000. The record indicates that the $50,000 came from Farnsworth's family. When the $50,000 was deposited, Farnsworth was required to agree as follows:

I authorize the Clerk of Court to use this bail bond to pay all fines, surcharges, costs and victim restitution that I may be ordered to pay by the District Court in the final judgment of this matter or any other criminal judgment against me in Cerro Gordo County.

Farnsworth was released pending trial.

Trial began in the Cerro Gordo County Courthouse on January 14, 2013. Farnsworth primarily relied on a defense of justification. Three days later, the jury returned a verdict finding Farnsworth guilty of the lesser included offense of second-degree murder. See Iowa Code § 707.3 (2012).

At Farnsworth's March 8 sentencing hearing, the district court imposed a sentence on the second-degree murder conviction of fifty years' incarceration with a mandatory minimum of 70%. See id.; id. § 902.12(1). The court added, "I'll enter an order separate from the sentencing order in regard to bond disposition." It continued, "Pursuant to Mr. Farnsworth's bond receipt agreement, I intend to forfeit the sums posted in his name for application toward victim restitution." The court further indicated that the parties would have ten days to object to this procedure.

The court's formal sentencing order, entered that day, directed Farnsworth to pay $150,000 in pecuniary damages to Decker's heirs at law pursuant to Iowa Code section 910.3B and $14,972 to the crime victim compensation program. It did not address Farnsworth's bond payments.

Twelve days later, on March 20, the court entered an...

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