State of Iowa v. Christopher Hutchcroft

CourtCourt of Appeals of Iowa
DecidedJune 16, 2021
Docket20-0301
StatusPublished

This text of State of Iowa v. Christopher Hutchcroft (State of Iowa v. Christopher Hutchcroft) is published on Counsel Stack Legal Research, covering Court of Appeals 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 Hutchcroft, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0301 Filed June 16, 2021

STATE OF IOWA, Plaintiff-Appellee,

vs.

CHRISTOPHER HUTCHCROFT, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Delaware County, Monica L. Zrinyi

Wittig, Judge.

Christopher Hutchcroft appeals the restitution order imposed by the district

court following his guilty pleas to first-degree theft, first-degree criminal mischief,

and third-degree burglary. REVERSED AND REMANDED.

Martha J. Lucey, State Appellate Defender, and Mary K. Conroy, Assistant

Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Martha E. Trout, Assistant Attorney

General, for appellee.

Considered by Vaitheswaran, P.J., and Tabor and Ahlers, JJ. 2

VAITHESWARAN, Presiding Judge.

Christopher Hutchcroft entered a largely vacant foreclosed building without

permission and took items exceeding $10,000 in value. He also damaged the

building by breaking pipes and fuse boxes, with the damage exceeding $10,000.

The State filed several charges. Hutchcroft pled guilty to first-degree theft, first-

degree criminal mischief, and third-degree burglary. The court later imposed

judgment and sentence, including an obligation to pay victim restitution.

The State filed a statement of pecuniary damages asserting the victim lost

$1,775,000. Following an evidentiary hearing, the district court concluded

Hutchcroft’s actions were “the direct cause of the damages to the electrical system

inside the building.” After requiring the State to present additional evidence to

support its requested amount of restitution, the court imposed a victim restitution

obligation of $707,000. Hutchcroft appealed.1

1 The State asserts Hutchcroft had to seek review by application for writ of certiorari and “[t]he grant of certiorari is unnecessary.” The State also sees “no good cause” for considering a direct appeal from a guilty plea pursuant to Iowa Code section 814.6 (2020). We are persuaded Hutchcroft had a right to file a direct appeal. See Iowa Code §§ 910.2(1)(a)(1) (“In all criminal cases in which there is a plea of guilty, . . . the sentencing court shall order that pecuniary damages be paid by each offender to the victims of the offender’s criminal activities . . . without regard to an offender’s reasonable ability to make payments.”); 2020 Iowa Acts ch. 1074, § 74 (to be codified at Iowa Code § 910.3(8) (2021) (“A permanent restitution order entered at the time of sentencing is part of the final judgment of sentence as defined in section 814.6 and shall be considered in a properly perfected appeal.” (emphasis added)); State v. Damme, 944 N.W.2d 98, 105 (Iowa 2020) (holding “good cause exists to appeal from a conviction following a guilty plea when the defendant challenges his or her sentence rather than the guilty plea”); State v. Jauregui, No. 20-0629, 2021 WL 1663598, at *1 n.1 (Iowa Ct. App. Apr. 28, 2021) (“The State agrees [the defendant] has good cause to appeal because he is challenging a component of his sentence as opposed to his guilty plea.”). 3

Hutchcroft contends “the record lacked substantial evidence supporting a

finding of $707,000 in pecuniary damages and the State failed to establish the

causal connection of that amount to [his] criminal offenses.” Hutchcroft correctly

notes that our review of the district court’s fact findings is for substantial evidence.

See State v. Roache, 920 N.W.2d 93, 99 (Iowa 2018); see also State v. Waigand,

953 N.W.2d 689, 695 (Iowa 2021) (stating sentencing courts “should not rubber-

stamp victim restitution claims” (quoting Roache, 920 N.W.2d at 108)). He is also

correct that “[t]he defendant’s criminal conduct must have been the cause in fact

of the loss and within the scope of liability.” Waigand, 953 N.W.2d at 694; Roache,

920 N.W.2d at 100.

The district court made the following pertinent findings. The court observed

the building “was being vandalized on a regular basis”; “[i]tems such as fuses, hose

clamp couplers, copper, breakers and other electrical components for the

building’s electrical system were being removed”; and “[t]he damage was not only

in the interior of [the] building as there was apparent tampering to the exterior

transfer box also.” A camera was placed on the building “due to the number of

reported break-ins.” Officers verified Hutchcroft was in the building “for over 4

hours on at least one occasion.” Hutchcroft testified he was inside the building

“maybe 3–4 times.” “He admitted to taking footings from the basement, wiring from

some of the electrical boxes, stainless steel fittings, copper and to dismantling a

breaker box.” “The items he stole he sold and garnered approximately $6,000.00–

$7,000.00 dollars.” The court further found:

When the police entered the building to video the interior, they found that every electrical box in the building had been destroyed, with wiring hanging out of the piping and fuses removed. The electrical 4

piping had been sawed to gain access to the wiring inside, which had been removed by the use of a winch. A review of [Hutchcroft’s] cell phone revealed he had been in and out of the building, at the very least, between the months of May through October of 2017.

The court determined Hutchcroft “owe[d] for damages to the electrical boxes and

any damage to the areas of where he entered and exited the building,” as well as

“the value of the fuses, the piping he cut to take out the wiring, the cost of the

wiring, the cost of copper he removed, and cost of the stainless steel fittings.” The

court stated the owner could “be compensated for the length of copper that

need[ed] to be purchased for replacement, not any more than that,” and he might

“be entitled to the cost for an electrical box, but not a new one.” The court found

the owner was “not entitled to a complete overhaul of the electrical system and he

[could] not be put in a better position than he was in prior to the illegal conduct.”

For example, the court noted there were “repair estimates for an HVAC

system . . . but there [was] no evidence to support [Hutchcroft] caused any

damage to the HVAC system.” The court ordered the State to provide “more

detailed information” that was “specific to the losses of” the owner so it could

“separate out repairs that [could] not be connected to” Hutchcroft.

In response, the State provided a letter from an electric repair company

stating in part, “[O]ur quote contained equipment I felt should be replaced with new

gear. The condition of the equipment in my opinion was too dangerous to be put

in operation and thus reflected in my quote to [the owner].” The district court

determined the letter failed to comply with its directive and ordered the State to

provide additional information. The State presented a second letter stating: 5

This letter is to establish an estimated cost for replacement of equipment, wiring and damages done to the industrial building used to process feed ingredients owned by Mr. Randy Less at 204 Locust Street, Hopkinton, IA.

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Related

State v. Ihde
532 N.W.2d 827 (Court of Appeals of Iowa, 1995)
State of Iowa v. Terran E. Roache
920 N.W.2d 93 (Supreme Court of Iowa, 2018)

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State of Iowa v. Christopher Hutchcroft, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-christopher-hutchcroft-iowactapp-2021.