State of Iowa v. Christopher Craig Hawk

CourtSupreme Court of Iowa
DecidedDecember 23, 2020
Docket19-1814
StatusPublished

This text of State of Iowa v. Christopher Craig Hawk (State of Iowa v. Christopher Craig Hawk) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Christopher Craig Hawk, (iowa 2020).

Opinion

IN THE SUPREME COURT OF IOWA No. 19–1814

Submitted November 18, 2020—Filed December 23, 2020

STATE OF IOWA,

Appellee,

vs.

CHRISTOPHER CRAIG HAWK,

Appellant.

Appeal from the Iowa District Court for Wayne County, Patrick W.

Greenwood, Judge.

The defendant appeals his restitution order. AFFIRMED.

Oxley, J., delivered the opinion of the court, in which all justices

joined.

Martha J. Lucey, State Appellate Defender, and Stephan J. Japuntich, Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, Tyler J. Buller, Assistant

Attorney General, and Alan M. Wilson, County Attorney, for appellee. 2 12/23/2020 8:00:45 AM

OXLEY, Justice.

Criminal restitution—specifically the determination of a defendant’s

ability to pay criminal restitution—has been the topic of numerous appeals

and recent legislation. The defendant seeks review of the amount of

restitution ordered by the district court, while the State argues recent

amendments to the restitution statutes preclude our review. We conclude

we can consider the district court’s order, which we affirm.

I. Background Facts and Proceedings.

Hawk was a passenger in his Jeep when his son ran a stop sign and

was stopped by police officers on September 2, 2018. Officers arrested

Hawk’s son for driving without a valid license. The officers conducted a

weapons pat down of Hawk as the passenger, discovered

methamphetamine in Hawk’s pocket, and arrested him too.

The State charged Hawk with possession of methamphetamine in an

amount greater than five grams with intent to distribute, in violation of

Iowa Code sections 124.401(1) and 124.401(b)(7) (2018), a Class “B”

Felony, and failure to affix a drug tax stamp, in violation of Iowa Code

sections 453B.1 and 453B.12, a Class “D” Felony. After a denied motion

to suppress and plea negotiations, Hawk pled guilty to possession of

methamphetamine in an amount less than five grams with intent to

distribute, in violation of Iowa Code section 124.401(1)(c)(6), a Class “C”

Felony. He does not appeal his guilty plea.

Hawk was sentenced on October 2, 2019, to the maximum sentence

of ten years in prison and ordered to pay a $1000 fine plus a 35%

surcharge. During sentencing, the district court considered Hawk’s ability

to pay court costs. According to the presentence investigation report,

Hawk claimed earnings of $12,000 in 2018 from unemployment. He

claimed debt from two vehicle loans totaling $18,000, both of which were 3 12/23/2020 8:00:45 AM

in default, $600 in credit card debt, and $2400 owed for court fees. At

sentencing, he testified he lost his Jeep to a $3400 towing bill following

his arrest and that he had been close to starting his own business when

he was arrested, although he did not elaborate on what type of business.

In considering whether to order Hawk to pay court costs and his

court-appointed attorney fees, the court concluded Hawk was “not

incapable” of working and would be able to repay some amount of

restitution. The court ordered Hawk to pay the full court costs of $343.50

but capped repayment of his court-appointed attorney fees at the lesser of

$250 or the actual amount of fees. Thus, the “second category”

restitution 1 ordered, apart from the $1000 fine, totaled $593.50. Hawk

appealed this restitution order on October 30, arguing the amount of

restitution was excessive.

II. Legal Analysis.

A. Jurisdiction to Hear Hawk’s Appeal. We initially retained this

case to determine whether we could hear Hawk’s appeal following a guilty

plea in light of the changes to Iowa Code section 814.6, which went into

effect on July 1, 2019. See Iowa Code § 814.6(1)(a)(3) (2020) (limiting

direct appeals from a final judgment of sentence following a guilty plea to Class “A” felonies or a showing of “good cause”). The State “assumes

without conceding” we have jurisdiction to hear Hawk’s appeal under the

1Prior to revisions enacted on June 25, 2020, the Iowa Code recognized two categories of restitution, the second of which could be ordered only if the defendant had the reasonable ability to pay the restitution. See Iowa Code § 910.2(1) (2019); id. § 910.2(1) (2018). Court costs and reimbursement for court-appointed attorney fees were both considered “second category” restitution to which the ability-to-pay determination applied. See id. § 910.2(2) (2019). Those items are now considered Category B restitution and are still subject to an ability-to-pay determination. See 2020 Iowa Acts ch. 1074, § 69 (to be codified at Iowa Code § 910.1(001) (2021)) (defining Category “B” restitution); id. § 71 (to be codified at Iowa Code § 910.2(1)(a)(2) (2021)). 4 12/23/2020 8:00:45 AM

good cause provision of section 814.6(1)(a)(3) where Hawk is appealing the

restitution order included in his sentence and not his guilty plea.

Since the time that we retained Hawk’s appeal, the legislature

enacted Senate File 457 (SF 457), which made changes to the criminal

restitution scheme. See 2020 Iowa Acts ch. 1074, §§ 65–83. In short,

SF 457 changed the procedure by which a defendant’s ability to pay

Category “B” restitution is determined, including shifting presumptions,

imposing statutory waivers, and requiring financial affidavits. See id. The

statutory amendments at issue took effect on June 25, 2020. Id. § 83.

The State argues that those changes apply retroactively to strip us of

jurisdiction to hear Hawk’s challenge to the restitution order.

Criminal defendants can be ordered to pay different types of

restitution. Some types of restitution such as restitution for pecuniary

damages incurred by victims of the defendant’s crimes, are not limited in

amount. See Iowa Code § 910.2(1) (2018). Regardless of a defendant’s

financial wherewithal, he must make restitution for the monetary damages

caused by his criminal actions. See id. Other types of restitution, such

as court costs and reimbursement of court-appointed attorney fees, are

limited to an amount the defendant is reasonably able to pay. See id. It

is not uncommon for the total amount of some of those items to not be

available at the time of sentencing. When that happens, we have directed

that district

[c]ourts must wait to enter a final order of restitution until all items of restitution are before the court. Once the court has all the items of restitution before it, then and only then shall the court make an assessment as to the offender’s reasonable ability to pay. 5 12/23/2020 8:00:45 AM

State v. Albright, 925 N.W.2d 144, 162 (Iowa 2019); see also Iowa Code

§ 910.3(9) (providing for temporary and supplemental orders “[i]f the full

amount of restitution cannot be determined at the time of sentencing”).

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