Rieflin v. Ault, No. C00-0011-MWB (N.D. Iowa 10/11/2001), C00-0011-MWB.
| Decision Date | 11 October 2001 |
| Docket Number | No. C00-0011-MWB.,C00-0011-MWB. |
| Parties | GERALD A. RIEFLIN, Petitioner, v. JOHN F. AULT, Warden, Respondent. |
| Court | U.S. District Court — Northern District of Iowa |
Before the court is a petition for a writ of habeas corpus, filed pursuant to 28 U.S.C. § 2254. Petitioner, Gerald A. Rieflin, is an inmate at the Anamosa State Penitentiary, Anamosa, Iowa. On May 29, 1997, following a jury trial, petitioner Rieflin was convicted of two counts of first-degree murder and two counts of assault with intent to inflict serious injury. The parties do not dispute the following underlying facts surrounding Rieflin's conviction as described by the Iowa Supreme Court:
In January 1995, Rieflin shot and killed two co-workers and wounded two other co-workers at the Ralston Foods plant in Cedar Rapids, Iowa. The shootings occurred in the presence of numerous onlookers. Rieflin was charged with two counts of first-degree murder, in violation of Iowa Code sections 707.1 and 707.2 (1993), and two counts of attempted murder, in violation of Iowa Code sections 707.11 and 902.7.
In February, following Rieflin's request for a medical evaluation at State expense, psychologist Dan Rogers examined him. Upon completion of his evaluation, Rogers prepared a psychological assessment report. In his report, Rogers concluded that Rieflin suffered from paranoid schizophrenia and, at that time, was incapable of assisting in his own defense. At a hearing on July 25, the district court held that, based upon Roger's report, there should be a hearing to determine Rieflin's competency to stand trial. The court ordered him to be evaluated at the Iowa Medical and Classification Center in Oakdale. On August 16, Rieflin filed a notice of defense of insanity and diminished responsibility. See Iowa R. Crim. P. 10(11)(b)(1).
Rieflin remained at Oakdale for an extended period and was evaluated and treated by psychiatrist R.T. Lara and clinical director P.L. Loeffelholz. They also diagnosed Rieflin as paranoid schizophrenic but found him competent to stand trial. At the competency hearing in December, defense counsel stated that as long as Rieflin is on medication that is administered properly, he is able to communicate and assist with his defense. Following the hearing, the district court concluded that Rieflin was competent to stand trial. The court relied, in part, on Lara's report, which stated: [Rieflin] does not have any intrusive mental condition which would prevent him from fulfilling the criteria established by the [Iowa] Code. Despite his diagnosis, he knows what he is charged with, knows the proceedings as explained to him, can meaningfully cooperate with counsel in his own defense, and can enter a thoughtful plea of his choosing.
In January 1996, Rieflin was evaluated by a psychiatrist of his own choosing, Dr. William Logan. After spending approximately three hours with him, Logan concluded that Rieflin was paranoid schizophrenic and incompetent to stand trial. Specifically, Logan stated that Rieflin continues to have delusions which affect his perception of the legal proceedings, and that his antipsychotic medication was not adequate to control his symptoms. Rieflin then requested another competency hearing, which was held on April 12. At this hearing, Logan's report was admitted into evidence. Also, the State presented the testimony of three witnesses: Nurse Jan Dolley, Dr. Mark Pospisil, and Sergeant John Hrmidko. The district court again issued an order, finding Rieflin competent to stand trial. The court stated:
There simply is no evidence presented in the record that the defendant is incapable of effectively assisting in his own defense. The only intellectual problem attributed to the defendant is his belief that he will be subject to attack by demons and that the deity will intervene in his behalf with the jury. The defendant's own expert acknowledges that the defendant's cognitive capacity is intact and that he understands that he is charged with murder and that he is at the Linn County Jail and that he understands the roles of the different participants in the proceeding. There is no indication that the defendant's recollection of the events which form the basis of the charge is impaired. In summary, there simply is no evidence that the defendant's mental condition has changed in any respect since the last time an order was entered concerning the defendant's competency.
Another hearing was held on April 26, during which defense counsel made a professional statement expressing his belief that Rieflin was incompetent. In its order, the district court denied Rieflin's motion to reconsider the prior ruling on competency and denied Rieflin's motion to change the judge. On May 9, we granted Rieflin's application for discretionary review and stayed all further proceedings in the district court.
State v. Rieflin, 558 N.W.2d 149, 150-51 (Iowa 1996), cert. denied, 520 U.S. 1216 (1997). The Iowa Supreme Court concluded that the district court had not erred in finding that Rieflin was competent to stand trial as well as an evidentiary issue concerning the admission of certain evidence at the competency hearings which Rieflin claimed violated his physician-patient privilege. Id. at 153. The following undisputed facts, as found by the Iowa Court of Appeals, occurred in the Iowa District Court following the remand from the
Iowa Supreme Court:
Procedendo issued on January 8, 1997. On the same date, the Supreme Court denied Rieflin's motion to stay further proceedings. Trial was scheduled by the district court judge for May 12, 1997.
On January 13, 1997, Rieflin filed an application seeking an additional evaluation by William S. Logan, M.D. Defense counsel stated concern that Rieflin's condition had deteriorated during the appeal process. Proceedings were held on said application on January 24, 1997. The following colloquy between the district court and defendant's counsel took place:
The district court issued a ruling on February 20, 1997, denying the application for an additional evaluation. The ruling states:
The motion for the psychiatric evaluation is filed by the defendant less than a month after the Iowa Supreme Court filed its ruling that the defendant was competent to stand trial. There is nothing in the application for psychiatric evaluation to indicate any change in the defendant's condition from the time of the last evaluation which led to my order of April 17, 1996, finding the defendant competent. . . . .
It does not, based on the information provided in the application filed by the defendant, reasonably appear that the defendant's condition is any different from what it was at the time of the last hearing.
IT IS, THEREFORE, ORDERED that the application for psychiatric evaluation filed by the defendant on January 13, 1997, is denied.
State v. Rieflin, 589 N.W.2d 749, 751-52 (Iowa Ct. App. 1998)
On May 12, 1997, trial was commenced and a guilty verdict was returned on May 29, 1997. On June 4, 1997, Rieflin was sentenced to life imprisonment on each of his murder convictions and indeterminate sentences of up to two year imprisonment on each of his assault with intent to inflict serious injury convictions.
Petitioner Rieflin appealed his convictions. The Iowa Court of Appeals affirmed his convictions on November 30, 1998. Rieflin, 589 N.W.2d at 753. On January 20, 2000, Rieflin filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. Rieflin's petition asserts one ground for relief: that his rights to due process under the Fifth and Fourteenth Amendments to the United States Constitution were violated when he was tried while incompetent to stand trial.
This case was referred to United States Magistrate Judge Paul A. Zoss pursuant to 28 U.S.C. § 636(b)(1)(B). On June 20, 2001, Judge Zoss filed a thorough and comprehensive Report and Recommendation in which he recommends that Rieflin's petition be denied. Rieflin filed objections to Judge Zoss's Report and Recommendation on July 27, 2001. The court, therefore, undertakes the necessary review of Judge Zoss's recommended disposition of Rieflin's petition for a writ of habeas corpus.
Pursuant to statute, this court's standard of review for a magistrate judge's Report and Recommendation is as follows:
A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made. A judge of the court may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate [judge].
28 U.S.C. § 636(b)(1). Similarly, ...
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