State of Iowa v. Lloyd B. Morrison

CourtCourt of Appeals of Iowa
DecidedOctober 5, 2022
Docket21-1647
StatusPublished

This text of State of Iowa v. Lloyd B. Morrison (State of Iowa v. Lloyd B. Morrison) 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. Lloyd B. Morrison, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1647 Filed October 5, 2022

STATE OF IOWA, Plaintiff-Appellee,

vs.

LLOYD B. MORRISON, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, John D. Telleen,

Judge.

Lloyd Morrison appeals from his guilty plea to assault with intent to commit

sexual abuse causing bodily injury. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Robert P. Ranschau,

Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Genevieve Reinkoester, Assistant

Attorney General, for appellee.

Considered by Bower, C.J., Tabor, J., and Doyle, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2022). 2

DOYLE, Senior Judge.

Lloyd Morrison appeals his conviction following his guilty plea to assault

with intent to commit sexual abuse causing bodily injury. He argues the district

court should have, sua sponte, ordered a pre-sentencing competency evaluation

and the court’s failure to do so violated his right to due process. He asks that we

vacate his guilty plea and sentence and remand to the district court for further

proceedings. Having failed to make a showing before the district court that a

reasonable person would believe that there is a substantial question of his

competency, we affirm Morrison’s conviction and sentence.

Morrison was charged with third-degree sexual abuse, habitual offender,

after grabbing the genital area of a female store employee. He later entered a

written guilty plea to assault with intent to commit sexual abuse causing bodily

injury. He waived his right to be present and participate in an in-court plea

colloquy. The district court accepted the paper plea, ordered a presentence

investigation report (PSI), and set a sentencing date. Morrison appeared at the

sentencing hearing and was sentenced to a period of incarceration. At no time did

Morrison or his counsel request a competency hearing. Morrison now claims the

PSI documented his “significant” mental-health issues such that the district court

should have, sua sponte, ordered a competency evaluation.

This is a direct appeal from Morrison’s guilty plea to a class “D” felony. Iowa

Code section 814.6(1)(a)(3) (2020) prevents defendant from challenging their

guilty pleas for anything but a class “A” felony unless they establish “good cause.”

So our threshold question is whether Morrison has good cause to appeal from his

plea. State v. Tucker, 959 N.W.2d 140, 153 (Iowa 2021). His claim the district 3

court erred in failing to, sua sponte, order a competency hearing established good

cause to appeal as a matter of right. State v. Newman, 970 N.W.2d 866, 870-71

(Iowa 2022) (citing State v. Chindlund, No. 20-1368, 2021 WL 2708944, at *2 (Iowa

Ct. App. June 30, 2021) (“[G]ood cause exists to challenge competency at the time

of the plea irrespective of whether the issue was contested below.” (quoting State

v. Cue, No. 19-2150, 2020 WL 6157813, at *3 (Iowa Ct. App. Oct. 21, 2020)))

further review denied (Dec. 22, 2020)).

Because the conviction of an incompetent person violates due process, we

review competency decisions de novo. State v. Einfeldt, 914 N.W.2d 773, 778,

780 (Iowa 2018). We “examine the totality of the circumstances to determine if, at

the relevant time, a substantial question of the [defendant]’s competency

reasonably appeared.” Jones v. State, 479 N.W.2d 265, 270 (Iowa 1991).

Throughout the district court proceedings, neither Morrison nor his counsel

mentioned Morrison’s competency. No one requested a competency evaluation.

The record of the hearings Morrison participated in give no indication that he

demonstrated irrational behavior during these proceedings or that his demeanor

was anything but normal considering the circumstances. Being a paper plea,

Morrison did not appear before the court taking the plea. That leaves for

consideration only the PSI presented to the sentencing judge and Morrison’s

conduct during the sentencing hearing. To be sure, the PSI outlines Morrison’s

mental-health difficulties, including a history of PTSD, anxiety, depression and

schizophrenia. A June 2020 psychiatric evaluation was conducted with the

following diagnosis: “Bipolar disorder type I manic episode, traumatic brain injury,

alcohol use disorder, and polysubstance use disorder.” Under “Offender 4

Intervention Comments,” the PSI states, among other things, “[a] mental health

evaluation is paramount with monitoring to ensure [Morrison] adheres to his follow

up care and medications.” But the PSI says nothing about Morrison’s competency

to stand trial. Morrison was cogent and apologetic at his sentencing hearing.

Nothing he said would have alerted a reasonable person to doubt Morrison’s

competency at the hearing.

There is a presumption that a defendant is competent to stand trial, and the

defendant has the burden to prove incompetence. Newman, 970 N.W.2d at 871.

When questions arise about a criminal defendant’s competency, Iowa Code

section 812.3 sets out a procedural mechanism to ensure due process is satisfied.

It requires a competency hearing “at any stage of a criminal proceeding” if there

are “specific facts showing that the defendant is suffering from a mental disorder

which prevents the defendant from appreciating the charge, understanding the

proceedings, or assisting effectively in the defense.” Iowa Code § 812.3(1). Either

a defendant or defense counsel can apply for a competency determination, or the

court can schedule a competency hearing on its own motion. See id.

“Probable cause exists for a competency hearing when a reasonable

person would believe that there is a substantial question of [Morrison]’s

competency.” Einfeldt, 914 N.W.2d at 779. Whether to hold a competency

evaluation to determine a defendant's competency to stand trial presents a legal

question; as a result, the trial court's discretion does not play a role. Id.

As noted, neither Morrison nor his attorney requested a competency

hearing. Should the sentencing court have ordered a competency hearing on its

own motion? In this case, to evaluate whether a hearing was required, we only 5

consider those competency factors known to the court at the time of the sentencing

hearing. See State v. Walton, 228 N.W.2d 21, 23 (Iowa 1975). Factors in

determining whether due process requires an inquiry into competency include

(1) the defendant’s irrational behavior, (2) demeanor at trial, and (3) any prior

medical opinion on competence to stand trial. State v. Lucas, 232 N.W.2d 228,

232 (Iowa 1982). “[T]he ultimate question of competency facing the judge [is]

whether the defendant is prevented from ‘appreciating the charge, understanding

the proceedings, or assisting effectively in the defense.’” Einfeldt, 914 N.W.2d at

791 (quoting Iowa Code § 812.3(1)).

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Related

Jones v. State
479 N.W.2d 265 (Supreme Court of Iowa, 1991)
State v. Walton
228 N.W.2d 21 (Supreme Court of Iowa, 1975)
State of Iowa v. Wonetah Einfeldt
914 N.W.2d 773 (Supreme Court of Iowa, 2018)

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