State of Iowa v. Eliot James Stowe

Court of Appeals of Iowa·Decided July 20, 2022·No. 21-0080·Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-0080

Filed July 20, 2022

STATE OF IOWA, Plaintiff-Appellee,

vs.

ELIOT JAMES STOWE, Defendant-Appellant.

Appeal from the Iowa District Court for Monona County, Zachary Hindman, Judge.

Eliot Stowe appeals his conviction for first-degree murder. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Vidhya K. Reddy, Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Sheryl Soich, Assistant Attorney General, for appellee.

Heard by Vaitheswaran, P.J., Badding, J., and Vogel, S.J.* *Senior judge assigned by order pursuant to Iowa Code section 602.9206 (2022).

VAITHESWARAN, Presiding Judge.

Eliot Stowe appeals his first-degree murder conviction. He argues the district court should have found him not guilty by reason of insanity. I. Background Facts and Proceedings Cheryl, described by her friend as “a real champion of the underdog,” took in her adult grandson, Eliot Stowe. When Cheryl uncharacteristically failed to show up for a work meeting, a Monona County sergeant went to her acreage to check on her.

Stowe answered the door. The sergeant, who had since learned there was an outstanding warrant on Stowe, arrested him and entered the home “to check on Cheryl’s possible well-being.” In a bedroom, he observed “a large mass of dried blood” on the floor and “more blood underneath the bed.” A search warrant was later executed on the home.

Cheryl’s body, wrapped in what appeared to be a large living room rug secured with duct tape, was found in a field about a mile and a half from her home. A roll of duct tape was picked up in the middle of a road. A burned baseball bat was found in a fire pit outside Cheryl’s garage. The deputy medical examiner testified that Cheryl sustained “blunt force injuries” caused by an object “like a bat.”

The State charged Stowe with first-degree murder. Stowe notified the district court of his intent to rely on an insanity defense. Following a bench trial, the court rejected the defense and found Stowe guilty. II. Insanity Defense The statutory insanity defense states:

A person shall not be convicted of a crime if at the time the crime is committed the person suffers from such a diseased or deranged condition of the mind as to render the person incapable of knowing the nature and quality of the act the person is committing or incapable of distinguishing between right and wrong in relation to that act. Insanity need not exist for any specific length of time before or after the commission of the alleged criminal act. If the defense of insanity is raised, the defendant must prove by a preponderance of the evidence that the defendant at the time of the crime suffered from such a deranged condition of the mind as to render the defendant incapable of knowing the nature and quality of the act the defendant was committing or was incapable of distinguishing between right and wrong in relation to the act.

Iowa Code § 701.4 (2018).

Stowe concedes that “the question is whether ‘there is substantial evidence to support the trial court’s conclusion the defendant did not prove by a preponderance of evidence he was insane when he committed the crimes.’” (Quoting State v. Wheeler, 403 N.W.2d 58, 61 (Iowa Ct. App. 1987), overruled on other grounds by State v. Reeves, 636 N.W.2d 22, 25 (Iowa 2001).) Stowe also concedes “credibility issues are left to the factfinder” and “a factfinder generally is not obliged to accept expert testimony, even if it is uncontradicted.” (Internal citations and quotations omitted.) But he asserts “expert testimony ‘should not be arbitrarily and capriciously rejected.’” (Citing Waddell v. Peet’s Feeds, Inc., 266 N.W.2d 29, 32 (Iowa 1978).) In his view, the district court “discarded” two expert opinions “in favor of its own observations and analysis—failing to account for the reality that inferences which can routinely and logically be drawn from a mind unafflicted by schizophrenia, will not necessarily apply to a mind that is so afflicted.”

Three experts testified on the insanity defense. Clinical psychologist Richard Frederick opined Stowe appeared “to be somebody who had

schizophrenia,” he was “treated for it,” and he “was doing pretty well.” At the same time, he discerned “some confusion in [Stowe’s] thinking at some level,” and he characterized the “disorganization of thinking” as a hallmark of schizophrenia. After several hours of conversation with Stowe, Dr. Frederick opined Stowe “clearly” did not “understand what [was] happening,” he was “in a state of unreality” when he killed his grandmother, and he “did not know” that the charged behavior “was wrong.”

Forensic psychologist Tracy Thomas, who was retained by the State to evaluate Dr. Frederick’s opinion, ultimately opined that Stowe “did know [the] nature and quality” of his behavior but he “had a diseased or deranged condition of the mind” that “caused him to be unable to distinguish between right and wrong.” She, too, interviewed Stowe and, like Dr. Frederick, she relied in part on Stowe’s “disorganization of thought,” which she defined as “illogical, garbled, nonsensical” thinking.

Psychiatrist James Dennert testified for the State. Following a document review, he saw “no evidence that Mr. Stowe was suffering any sort of acute psychiatric or psychotic condition.” He did reason that Stowe may have personality disorder and was possibly suffering from schizophrenia, but he opined Stowe “did not suffer a mental impairment, illness, or derangement at the time of the event that would prevent him from being able to understand the nature and consequences of his actions, nor prevent him from being able to understand the difference between right and wrong.”

The district court thoroughly evaluated each of the three expert opinions.

The court found Dr. Dennert “credibly” focused on Stowe’s “mental state from

closest in time to when he killed Cheryl.” In contrast, the court noted that Drs. Frederick and Thomas relied on Stowe’s after-the-fact, self-serving statements. The court contrasted those statements with Stowe’s rational behaviors around the time of the killing, citing the following pieces of evidence among others:

• The “manner” in which Stowe killed Cheryl: “he inquired of Cheryl what would happen if he hit her with a baseball bat; he listened to her answer, that she would probably die; he went and retrieved a baseball bat; he followed her to the bedroom where she went to try to get away from him; he attempted unsuccessfully to open the bedroom door; he broke out a panel of the bedroom door; he reached through the panel and hit her with the baseball bat; he opened the door and hit her more; and then once Cheryl had crawled under the bed, he sat, smoked a cigarette, and waited for her to die.”

• Stowe’s “efforts at hiding the evidence” of Cheryl’s killing: he “rolled her or her body up in two rugs; thoroughly secured the rugs with duct tape; obtained the keys required to access one of Cheryl’s vehicles; placed butcher paper in the back of the vehicle in order to soak up any of Cheryl’s blood that may have leaked from her body; carried her body from her residence to the vehicle, and placed it inside the vehicle;

searched for a place to dump Cheryl’s body; decided to dump her body off of a low-maintenance Level B access road, . . .

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State of Iowa v. Eliot James Stowe, (iowactapp 2022).

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Related

State v. Jacobs
607 N.W.2d 679 (Supreme Court of Iowa, 2000)
State v. Wheeler
403 N.W.2d 58 (Court of Appeals of Iowa, 1987)
Waddell v. Peet's Feeds, Inc.
266 N.W.2d 29 (Supreme Court of Iowa, 1978)
State v. Reeves
636 N.W.2d 22 (Supreme Court of Iowa, 2001)