State v. Thompson
| Decision Date | 18 November 2022 |
| Docket Number | 20-1689 |
| Citation | 982 N.W.2d 116 |
| Parties | STATE of Iowa, Appellee, v. Christopher William THOMPSON, Appellant. |
| Court | Iowa Supreme Court |
Martha Lucey, Appellate Defender, and Theresa R. Wilson (argued), Assistant Appellate Defender, for appellant.
Thomas J. Miller, Attorney General, and Timothy M. Hau (argued), Assistant Attorney General, for appellee.
Christensen, C.J., delivered the opinion of the court, in which all participating justices joined. Mansfield, J., filed a concurring opinion, in which Waterman, J., joined. May, J., took no part in the consideration or decision of this case.
The defendant's mother sent this email to his probation officer hours before the defendant killed her by repeatedly hitting her with a crowbar. At trial, the defendant admitted to killing his mother but argued he was not guilty of first-degree murder because he acted impulsively out of rage. Over the defendant's objection, his probation officer and his mother's friend testified about his mother's fear of the defendant and her plan to stop financially supporting him. The jury found the defendant guilty of first-degree murder.
The defendant appealed, claiming the district court erred in admitting the testimony from the probation officer and his mother's friend as statements of the mother's then-existing mental state under Iowa Rule of Evidence 5.803(3) because her state of mind was not relevant. The court of appeals affirmed. On our review, we agree. The victim's statements were relevant to proving the defendant's intent and motivation at the time of the crime, so the district court correctly admitted them under rule 5.803(3).
After repeated attempts to get in touch with her friend, Paula Thompson (Paula), Lorie Baker contacted Paula's son, Christopher Thompson (Thompson), who informed her that Paula was not responding to Baker's messages because she was on a drinking binge. Nevertheless, Baker continued her attempts to reach Paula by phone and online messages. After failing to reach Paula for a few days, Baker called Thompson on March 18, 2020, to inform him that Paula was going to get fired if she did not report to work that day. Thompson replied, He instructed Baker to call the police.
Thompson waited a few hours after speaking to Baker "thinking they'd have a warrant out [for his arrest] by then" before walking into the Polk County Jail and declaring that there was a warrant for his arrest. When asked why there would be a warrant, Thompson stated he had killed his mother. Around the same time, Baker called 911 to do a welfare check on Paula and report what Thompson had said about killing Paula. Responding officers found Paula dead on her bedroom floor.
Thompson also threw a towel over Paula's head and placed rugs over the blood on the floor to keep from stepping in it.
When asked why the fight escalated, Thompson claimed Paula would not let him close his bedroom door and "was in his face." Thompson "just snapped," and he revealed that this was when he walked through the kitchen to get to the back stairway and retrieve the crowbar from the toolset. Upon further questioning, Thompson reported that there was no argument with Paula after he grabbed the crowbar. Rather, he went up to Paula and immediately hit her in the head with the crowbar, causing her to fall down. Thompson proceeded to "hit her a few more times and she stopped moving."
He estimated that he hit Paula "like seven" times. When asked what was going through his mind, Thompson answered, "rage," and explained, "I wanted it to be over." He stated he stopped hitting Paula after he saw all of the blood and realized she was dead, then washed the crowbar in the kitchen sink because it was dripping blood.
After Thompson explained what he did to Paula, the interviewers asked him what happened to Paula's cat. Thompson said he "just got rid of it" because "it wasn't [his] cat." Upon further questioning, Thompson admitted to killing the cat by hitting it with the same crowbar that he used to hit Paula, reasoning he was "still pissed" about everything related to Paula and the cat was hers. Thompson did not believe there was any of the cat's blood on the crowbar and expressed surprise that the cat "just broke" when he hit it. He grabbed the dead cat by the neck and threw it in the garbage can outside. Thompson also smashed Paula's cell phone.
Until he went to the Polk County Jail on March 18, Thompson claimed he only left the house to buy more alcohol after killing Paula and the cat. He told the interviewers that he had initially lied to Baker about Paula being on a drinking binge, but he was having trouble sleeping and felt compelled to admit what he did on March 18. After Thompson's interview, the State charged him with first-degree murder, a class "A" felony, in violation of Iowa Code sections 707.1 and 707.2(1) (2020), as well as animal abuse, an aggravated misdemeanor, in violation of Iowa Code section 717B.2. Thompson separately pleaded guilty to the animal abuse charge.
A. Pretrial Evidentiary Issues. Before trial, the State filed a motion requesting a hearing under Iowa Rule of Evidence 5.104(a ) to determine the admissibility of testimony from two witnesses—Melissa Moylan and Maggie Wood—under either Iowa Rule of Evidence 5.404(b ) involving prior bad acts or 5.803(3) regarding the declarant's then-existing mental state. Moylan was a close friend of Paula's, and the State sought to admit testimony from Moylan about conversations she had with Paula about Paula and Thompson's relationship.
Specifically, Paula shared with Moylan that [Thompson] was abusive. In December 2019, Moylan watched a video that was posted to Paula's Facebook page. In the video, Paula whispers that if anything happens to her, it was [Thompson] who killed her. Additionally, approximately one month before Paula's death, Paula confided in Moylan that she and [Thompson] had a heated argument regarding finances. Paula told [Thompson] that she was done supporting him and that he needed to move out of her house. [Thompson] was upset because he didn't want to work. Paula cut up [her] credit cards in front of him. Paula told Moylan that she was afraid of [Thompson]. She said that [Thompson] was drinking again, but she didn't know how he was getting his alcohol without an income.
The State also sought to admit testimony from Wood, Thompson's probation officer at the time of his arrest in this case, regarding an email Paula sent her at 5:49 p.m. on the night she died expressing her fear of Thompson. The email stated, Wood would also testify that she knew the email came from Paula because Paula had emailed her before about Thompson.
Following a hearing, the district court ruled Paula's statements about being afraid that Thompson might kill her, that she was done financially supporting Thompson, and her desire to get Thompson out of the house were admissible under Iowa Rule of Evidence 5.803(3) as statements of Paula's then-existing mental, emotional, or physical condition. It also allowed the State to introduce testimony from Moylan about Paula's Facebook video under the same rule so long as the evidence that Paula later withdrew the video and told others she was fine was also admitted. The district court reserved ruling on additional statements until trial.
At the final pretrial conference, Thompson again objected to the district court's ruling on the admissibility of the challenged evidence. He also explained that he would make a general objection again at trial to the witnesses’ testimony based on the rule 104(a ) hearing. The district court denied Thompson's renewed objection.
B. Thompson's Trial. A jury trial concerning Thompson's first-degree murder charge commenced on November 2. Throughout the trial, Thompson acknowledged killing Paula, but he argued he was guilty of "either voluntary manslaughter or murder in the second degree" instead of first-degree murder. Namely, Thompson argued he killed his mother as an act of passion and provocation instead of an act that was willful, deliberate, and premeditated. He did not testify.
Baker testified about her attempts to reach Paula and her interactions with Thompson during that time, including Thompson's admission to her that he killed Paula with a crowbar. Moreover, the medical examiner testified about the extent of Paula's injuries and jail staff testified about their interactions with Thompson when he turned himself in at the Polk County Jail. The jury also heard from one of the interviewing detectives and watched the detectives’ recorded interview with Thompson, the responding officer's body camera footage discovering Paula's body, and video footage of the crime scene. Similarly, it listened to Baker's 911 call reporting what Thompson told her...
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