Farnsworth v. State
Decision Date | 18 November 2022 |
Docket Number | 20-0786 |
Citation | 982 N.W.2d 128 |
Parties | James FARNSWORTH II, Appellant, v. STATE of Iowa, Appellee. |
Court | Iowa Supreme Court |
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.
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).
In 2014, the court of appeals affirmed James Farnsworth's second-degree murder conviction, summarizing the relevant facts as follows:
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 order as to the bond. The order exonerated the $150,000 in cash bond posted by the bonding company while stating that the court "intend[ed] to forfeit" the $50,000 in cash bond posted in Farnsworth's name "for application toward victim restitution." The clerk was directed to hold the latter funds in trust "until further order of the court, which will enter upon the opening [of] a probate estate of Ian Decker, the appointment of a conservator for the minor heir of Ian Decker, or the establishment of a trust for the benefit of the minor heir of Ian Decker." The court's order added, "In the absence of a written...
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