State v. Crooks
Decision Date | 20 April 2018 |
Docket Number | No. 16-0851,16-0851 |
Citation | 911 N.W.2d 153 |
Parties | STATE of Iowa, Appellee, v. Noah Riley CROOKS, Appellant. |
Court | Iowa Supreme Court |
Mark C. Smith, State Appellate Defender, and Martha J. Lucey, Assistant Appellate Defender, for appellant.
Thomas J. Miller, Attorney General, and Bridget A. Chambers and Denise A. Timmins, Assistant Attorneys General, for appellee.
In this appeal, we must decide challenges to Iowa’s youthful offender laws raised by a defendant who at age thirteen fatally shot his mother. The State prosecuted him as a youthful offender in district court, and a jury found him guilty of second-degree murder. When he reached age eighteen, the district court sentenced him to an indeterminate prison term of up to fifty years (with no mandatory minimum). The defendant raises statutory and constitutional challenges to his prosecution and sentence, arguing that as a thirteen-year-old offender, his case should have remained in juvenile court and that at age eighteen he should have been released on probation or placed in a transitional facility rather than prison.
We retained his appeal and, for the reasons explained below, affirm his conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility. We conclude the district court properly exercised its discretion based on an individualized assessment of this defendant under a constitutional statutory scheme. We acknowledge sentencing reform efforts nationwide to raise the minimum age for prosecution in adult court. But under our constitutional separation of powers, those efforts should be directed to the legislature.
On the evening of March 24, 2012, Noah Crooks was at home with his mother, Gretchen Crooks. Noah was thirteen years old and an eighth grader at Osage Middle School. He had no prior criminal record. The Crooks lived in rural Osage, in Mitchell County. Gretchen worked as a nurse at Mercy Hospital in Mason City and was studying to get her master’s degree at the University of Iowa. Noah’s father, William Crooks, worked at Cargill Kitchen Solutions in Mason City. William and Gretchen had been married for seventeen years.
William was at a work-related party away from home that evening when Noah loaded a .22 caliber rifle upstairs. Noah took the loaded rifle downstairs and saw his mother in the kitchen facing away from him. She was making dinner for him. Noah later told a child psychiatrist that he could not shoot her at that moment because it would not be honorable to shoot his mother in the back. Noah returned upstairs until his mother called up to say his dinner was ready. He returned downstairs with the rifle and this time found his mother sitting on the living room sofa studying her coursework. Noah shot her twenty-two times, killing her.
Noah sent his dad a text message at 7:30 p.m. The message stated, William thought Noah was joking and replied,
Deputy Jeff Huftalin was dispatched to the Crooks’s residence and knocked on the front door. Noah answered the door while he was still on the phone with the dispatcher. Deputy Huftalin asked Noah where his mother was. Noah told him she was in the living room and that the gun was on a chair. Deputy Huftalin asked Noah to sit on the porch while he entered the house. Deputy Huftalin found Gretchen slouched on the couch; he could see bullet holes in her chest. Gretchen’s pajama top was unbuttoned, and she was naked from the waist down. Deputy Huftalin confirmed that Gretchen was dead. He handcuffed Noah and put him in the backseat of the patrol car.
Deputy Huftalin called William to tell him there had been an accident in his house and that he needed to come home. Upon arrival, William was told that Gretchen was dead and that Noah had shot her.
The State filed a delinquency petition four days later, alleging that Crooks, age thirteen, committed the delinquent acts of first-degree murder and assault with the intent to commit sexual abuse. The State requested that the juvenile court waive jurisdiction so that Crooks could be tried as a youthful offender in adult court, as provided in Iowa Code section 232.45(7) (2011). Crooks filed a motion to dismiss, challenging the juvenile court’s statutory authority to waive jurisdiction over a thirteen-year-old. The juvenile court denied the motion. Crooks then filed a second motion to dismiss, this time asserting the youthful offender statute was unconstitutional. The juvenile court denied this motion, finding Crooks failed to establish that the statute was unconstitutional.
At the waiver-of-jurisdiction hearing, the juvenile court made the three findings required by Iowa Code section 232.45(7)(a ) for transfer to district court: (1) Crooks was fifteen years of age or younger, (2) there was probable cause that Crooks committed the forcible felonies alleged in the petition, and (3) the State had established that there were no reasonable prospects for rehabilitating Crooks prior to his eighteenth birthday if the juvenile court retained jurisdiction. The juvenile court waived jurisdiction over Crooks and transferred the case to the district court for Noah’s prosecution as a youthful offender.
The State filed a trial information in district court, alleging murder in the first degree and assault with intent to commit sexual abuse. The jury trial began on April 30, 2013. Crooks raised the defenses of insanity and diminished responsibility. On May 13, the jury returned a verdict finding him guilty of murder in the second degree and not guilty of assault with the intent to commit sexual abuse. The court placed him on youthful offender status and transferred his supervision to the juvenile court for disposition under Iowa Code section 232.52.
After conducting a dispositional hearing, the juvenile court transferred guardianship of Crooks to the director of the Department of Human Services for placement at the State Training School in Eldora. Crooks was under the supervision of the juvenile court until his eighteenth birthday. The juvenile court conducted yearly review hearings, and Crooks remained at the State Training School. He attended school and participated in mental health treatment. He graduated from high school on May 29, 2015.
The district court ordered a presentence investigation (PSI). The PSI report recommended incarceration:
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...Izzolena , 609 N.W.2d 541, 545 (Iowa 2000) (en banc). We review the district court's sentence for abuse of discretion. State v. Crooks , 911 N.W.2d 153, 161 (Iowa 2018).III. Legal Analysis.A. Does Iowa Code Section 910.3B(1) Apply Only to Defendants Convicted of a Crime in Which an Element ......
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State v. Wright
...(Iowa 2018) (Mansfield, J., dissenting) (beginning constitutional analysis with the text and original understanding); State v. Crooks, 911 N.W.2d 153, 167 (Iowa 2018) ("In exercising our independent judgment, we are 'guided by "the standards elaborated by controlling precedents and by [our]......
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...v. Izzolena, 609 N.W.2d 541, 545 (Iowa 2000) (en banc). We review the district court's sentence for abuse of discretion. State v. Crooks, 911 N.W.2d 153, 161 (Iowa 2018). III. Legal Analysis. A. Does Iowa Code Section 910.3B(1) Apply Only to Defendants Convicted of a Crime in Which an Eleme......