State v. Einfeldt, No. 16-0955

CourtUnited States State Supreme Court of Iowa
Writing for the CourtAPPEL, Justice.
Citation914 N.W.2d 773
Parties STATE of Iowa, Appellee, v. Wonetah EINFELDT, Appellant.
Docket NumberNo. 16-0955
Decision Date27 April 2018

914 N.W.2d 773

STATE of Iowa, Appellee,
v.
Wonetah EINFELDT, Appellant.

No. 16-0955

Supreme Court of Iowa.

Filed April 27, 2018
Rehearing Denied July 17, 2018


Mark C. Smith, State Appellate Defender, and Vidhya K. Reddy, Assistant Appellate Defender, Des Moines, for appellant.

Thomas J. Miller, Attorney General, Louis S. Sloven, Assistant Attorney General, Wayne Reisetter, County Attorney, and Stacy L. Ritchie and Ronald Forsell, Assistant County Attorneys, for appellee.

APPEL, Justice.

This appeal involves an important intersection involving mental illness and the criminal justice system. In this case, a criminal defendant’s lawyer moved midtrial for a competency examination of his client who, due to the stresses of trial was "incapable of aiding [him] in her defense." The record reveals that the client, among other things, testified she suffered from paranoid schizophrenia but had stopped taking prescribed medications due to lack of funds, stated that she wanted to stab her lawyer in the neck and wanted to kill him, declared that she did not know why her lawyer was sitting next to her, told the court that she had called the FBI and was told she did nothing wrong, and further declared that she would not write notes to her lawyer during trial for fear the lawyer would pass the notes to the prosecution. The district court denied the motion and the case proceeded to verdict. On appeal, the defendant claims the district court erred in not ordering a competency examination and in excluding evidence. For the reasons expressed below, we reverse the judgment of the district court and remand the case for further proceedings.

I. Factual Background.

Wonetah Einfeldt and her two daughters were charged with willful injury causing bodily injury over a physical altercation between the three women and a fourth woman named Mulika Vinson on July 14, 2015. The case went to trial and the defendants were tried jointly.

Prior to trial, the State sought to exclude all character evidence about the victim, Vinson. This included evidence related to Vinson’s prior threatening behavior and her convictions for two assaults and an escape in Nebraska in 2001. She was fifteen or sixteen years old at the time of the first assault and nineteen years old at the time of the second assault. At the time of trial, Vinson was thirty-one years old. Further, the State sought to exclude evidence of a shooting that occurred at Einfeldt’s apartment complex the evening of the altercation between Einfeldt, Einfeldt’s daughters, and Vinson. The State asserted that the police found no evidence of Vinson’s

914 N.W.2d 776

involvement in the shooting or that the shooting was directed at Einfeldt. Finally, the State sought to specifically exclude testimony by Lacey Chicoine about Vinson’s reputation for violence.

Einfeldt resisted this part of the motion in limine. She argued that this character evidence was admissible due to her self-defense justification defense rendering Vinson’s character relevant and probative. With respect to the shots fired the evening of the altercation, Einfeldt argued that the evidence was relevant because it supported Einfeldt’s belief that Vinson was a danger to her and others.

At a pretrial hearing, the district court judge reserved ruling on the admissibility of Vinson’s prior felonies. The court sustained the part of the State’s motion in limine with respect to the shots fired at Einfeldt’s apartment complex, but emphasized that this was a preliminary ruling and stated that Einfeldt could make an offer of proof at trial at which point the court might reconsider its ruling. With respect to Chicoine’s testimony about Vinson’s reputation, the court stressed that proper foundation would have to be laid to show that Chicoine was aware of Vinson’s reputation.

After jury selection, but before the presentation of evidence, Einfeldt again raised the issue of Vinson’s prior felony convictions. The district court found that the probative value of the evidence was outweighed by its danger of unfair prejudice, given how long ago the convictions happened and Vinson’s age at the time.

Later during trial, an attorney for one of Einfeldt’s daughters made an offer of proof concerning Chicoine’s testimony about Vinson outside the presence of the jury. Chicoine related that at one point she and Vinson were dating the same man, and Vinson threatened to "kick [Chicoine’s] ass" or "beat [her] up" if Chicoine didn’t stay away from the man. These threats were verbally made to Chicoine over the course of six months. Vinson never assaulted Chicoine, however. Chicoine was not aware of Vinson ever assaulting anyone.

The district court found that Chicoine’s testimony about threats was only marginally relevant to the issue of Vinson’s character trait of being prone to physical aggression. The court noted that Vinson only made threats and never assaulted Chicoine. The court thus excluded the evidence as more prejudicial than probative.

When Einfeldt made an offer of proof about the shots-fired incident at her apartment complex, the court ruled that evidence about the incident was inadmissible. The court found that the victim’s character could not be proven by a specific instance of conduct in this case or, alternatively, that there was not clear proof that Vinson was involved in the shooting, and so the probative value of the evidence was outweighed by the danger of unfair prejudice.

At the beginning of the third day of trial, Einfeldt’s attorney advised the court that his client did not remember the events of the previous day. He called his client to the stand to further make a record for the purpose of seeking a competency evaluation under Iowa Code chapter 812 (2015). When asked if she remembered the events of yesterday, Einfeldt responded, "No, I guess not. I don’t know." She testified that she did not remember calling the prosecutor a liar or that she slammed her hand down and was animated with her lawyer. Further, Einfeldt volunteered, "I just want to kill you [her lawyer]."

Einfeldt testified that she thought her lawyer was taking her written notes and giving them to the State and to other

914 N.W.2d 777

parties.1 She admitted that she told her lawyer that she wanted to stab him "with my pen in your neck." When asked if she could pay attention to the trial, be helpful to her lawyer, and assist the court when asked to do things, she responded, "Yeah. Yeah, I don’t know, I don’t hear any noises. It’s not buzzing. I just really—I’m in control." Einfeldt volunteered that someone was "poisoning the water." In light of this testimony, her lawyer told the court that Einfeldt has suffered from mental health issues in the past and that "the stress of the trial has caused her to be incapable of aiding [him] in her defense."

When the district court asked her if she could assist her counsel, Einfeldt said, "I just, I believe that I don’t—I kind of don’t, really. I do, but I don’t know who he is sometimes. Right now I don’t know why he’s sitting by me. I don’t understand this." Einfeldt recognized, however, that the person sitting next to her was her attorney. When the district court asked whether she understood the charges, she stated, "I don’t, honestly. I called the F.B.I., and they said they don’t think I did anything wrong."

When asked by the district court if she understood that she was being tried for the assault of Vinson, she responded, "I guess I don’t know what assault means, because I think that I have a right to defend myself." When asked if she thought she had a defense to the charge, Einfeldt responded, "Yeah. I don’t know."

Einfeldt told the district court that she had been diagnosed with paranoid schizophrenia, bipolar disorder, posttraumatic stress disorder, and attention deficit disorder. She stated she had prescriptions for these disorders but had not been taking her medication for a couple of months because she did not have the money.

The district court denied the request to suspend the proceedings and order a chapter 812 examination. The district court concluded that based on its observations, Einfeldt was capable of assisting counsel in providing a defense and understood the nature of the charges against her.

The district court revisited the question prior to sentencing. At this juncture, the district court had the opportunity to review Einfeldt’s medical records as well as a presentence investigation (PSI) report prepared by the department of correctional services.

The medical records from 2013 showed a provisional diagnosis at Broadlawns Medical Center (Broadlawns) of paranoid schizophrenia. The records stated that Einfeldt reported leaving Minnesota because people wanted to kill her. She further stated that the television talked to her. Her thought processes were characterized in the records as delusional. A regime of drug therapy was prescribed.

The PSI report, among other things, noted that Einfeldt had been diagnosed

914 N.W.2d 778

with "Schizo-Affective Disorder and Bipolar Depression" at Broadlawns. She had episodes of paranoia in the past and had received treatment for mental health issues. Based on Einfeldt’s self-report, and corroborated in the interview, the PSI report stated...

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23 practice notes
  • State v. Veal, No. 17-1453
    • United States
    • United States State Supreme Court of Iowa
    • May 24, 2019
    ...Notably, Veal cites nothing from the trial itself that might have suggested he was not competent to stand trial. Cf. State v. Einfeldt , 914 N.W.2d 773, 776–77 (Iowa 2018) (discussing behavior and statements of the defendant during trial).11 X. Excluded Evidence.Veal challenges the district......
  • State v. Draine, No. 18-1292
    • United States
    • Iowa Supreme Court
    • December 6, 2019
    ...to insist on making a factual clarification and argue why it should mitigate his punishment. State v. Einfeldt is a different case. See 914 N.W.2d 773 (Iowa 2018). There, the defendant had a prior diagnosis of mental illness and was engaging in bizarre courtroom behavior. See id. at 781–83.......
  • State v. Williams, No. 17-1989
    • United States
    • Iowa Supreme Court
    • May 24, 2019
    ...to prove a homicide victim’s aggressive character. See State v. Webster , 865 N.W.2d 223, 243–44 (Iowa 2015) ; State v. Einfeldt , 914 N.W.2d 773, 783–84 (Iowa 2018). Yet we did say in Einfeldt , "[I]f the accused asserts he or she acted in self-defense, specific instances of the victim’s c......
  • State v. Lacey, 20-0030
    • United States
    • United States State Supreme Court of Iowa
    • December 30, 2021
    ...we balance the probative value against the danger of its prejudicial or wrongful effect upon the triers of fact." State v. Einfeldt , 914 N.W.2d 773, 784 (Iowa 2018) (quoting State v. Webster , 865 N.W.2d 223, 242 (Iowa 2015) ). "The relevant inquiry is not whether the evidence is prejudici......
  • Request a trial to view additional results
21 cases
  • State v. Veal, No. 17-1453
    • United States
    • United States State Supreme Court of Iowa
    • May 24, 2019
    ...Notably, Veal cites nothing from the trial itself that might have suggested he was not competent to stand trial. Cf. State v. Einfeldt , 914 N.W.2d 773, 776–77 (Iowa 2018) (discussing behavior and statements of the defendant during trial).11 X. Excluded Evidence.Veal challenges the district......
  • State v. Draine, No. 18-1292
    • United States
    • Iowa Supreme Court
    • December 6, 2019
    ...to insist on making a factual clarification and argue why it should mitigate his punishment. State v. Einfeldt is a different case. See 914 N.W.2d 773 (Iowa 2018). There, the defendant had a prior diagnosis of mental illness and was engaging in bizarre courtroom behavior. See id. at 781–83.......
  • State v. Williams, No. 17-1989
    • United States
    • Iowa Supreme Court
    • May 24, 2019
    ...to prove a homicide victim’s aggressive character. See State v. Webster , 865 N.W.2d 223, 243–44 (Iowa 2015) ; State v. Einfeldt , 914 N.W.2d 773, 783–84 (Iowa 2018). Yet we did say in Einfeldt , "[I]f the accused asserts he or she acted in self-defense, specific instances of the victim’s c......
  • State v. Lacey, No. 20-0030
    • United States
    • United States State Supreme Court of Iowa
    • December 30, 2021
    ...we balance the probative value against the danger of its prejudicial or wrongful effect upon the triers of fact." State v. Einfeldt , 914 N.W.2d 773, 784 (Iowa 2018) (quoting State v. Webster , 865 N.W.2d 223, 242 (Iowa 2015) ). "The relevant inquiry is not whether the evidence is prejudici......
  • Request a trial to view additional results

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