State of Iowa v. Trevon Fox

CourtCourt of Appeals of Iowa
DecidedOctober 15, 2014
Docket13-1429
StatusPublished

This text of State of Iowa v. Trevon Fox (State of Iowa v. Trevon Fox) 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. Trevon Fox, (iowactapp 2014).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 13-1429 Filed October 15, 2014

STATE OF IOWA, Plaintiff-Appellee,

vs.

TREVON FOX, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Todd A. Geer,

Judge.

A defendant appeals his conviction for riot. REVERSED AND

REMANDED.

Mark C. Smith, State Appellate Defender, and Rachel C. Regenold and

Dennis D. Hendrickson, Assistant Appellate Defenders, for appellant.

Thomas J. Miller, Attorney General, Jean C. Pettinger, Assistant Attorney

General, Joseph Williams, Student Legal Intern, Thomas J. Ferguson, County

Attorney, and Peter Blink, Assistant County Attorney, for appellee.

Considered by Vaitheswaran, P.J., and Doyle and McDonald, JJ. 2

MCDONALD, J.

This case presents the question of whether a criminal defendant can be

prosecuted for a greater offense after appearing for trial on a lesser-included

offense, pleading guilty to the lesser-included offense in the presence of and

without objection by the prosecutor, and being convicted and sentenced for the

same. We conclude, under the facts and circumstances of this case, the Double

Jeopardy Clause bars prosecution for the greater offense following conviction for

the lesser-included offense.

I.

On January 2, 2013, the State filed a complaint against Trevon Fox,

charging him with disorderly conduct, in violation of Iowa Code section 723.4(1)

(2011), in connection with a New Year’s Eve bar brawl. Fox pleaded not guilty to

the offense, and trial was set for March 28. On February 26, the State filed a trial

information charging Fox with criminal gang participation and riot, in violation of

Iowa Code sections 723A.2 and 723.1, arising out of the same incident. The

State concedes disorderly conduct is a lesser-included offense of riot.

Fox and the prosecutor appeared for trial on the disorderly conduct charge

on the scheduled trial date. After the court informed Fox that he would not have

the assistance of appointed counsel for trial, Fox pleaded guilty to the charge of

disorderly conduct. The court convicted and sentenced Fox for that offense on

the same date. The record reflects the prosecutor appeared for trial and the plea

proceeding. There is no record of the prosecutor objecting to the guilty plea or

taking any other action of record to indicate the State would continue to pursue

prosecution for the greater offense of riot. 3

On May 2, 2013, Fox moved to dismiss the charges of gang participation

and riot on the ground the “Double Jeopardy Clause prohibits subsequent trial for

a greater offense after a conviction of a lesser-included offense.” The district

court overruled Fox’s motion. A jury found Fox guilty of riot and not guilty of the

gang participation charge, and the district court imposed sentence on the riot

charge. Fox filed this appeal, claiming the district court erred in denying his

motion to dismiss the riot charge.

II.

The Double Jeopardy Clause of the United States Constitution provides

no person shall “be subject for the same offense to be twice put in jeopardy of life

or limb.” U.S. Const. amend. V. This guarantee is applicable to state criminal

proceedings through the due process provision of the Fourteenth Amendment.

Benton v. Maryland, 395 U.S. 784, 794 (1969).

The Double Jeopardy Clause affords the defendant three basic

protections. “It protects against a second prosecution for the same offense after

an acquittal. It protects against a second prosecution for the same offense after

conviction. And it protects against multiple punishments for the same offense.”

Ohio v. Johnson, 467 U.S. 493, 498 (1984). The greater offense is by definition

the same offense for purposes of double jeopardy as the lesser offenses

included within it. See Brown v. Ohio, 432 U.S. 161, 165-66 (1977). Thus,

“[w]hatever the sequence may be, the Fifth Amendment forbids successive

prosecution and cumulative punishment for a greater and lesser included

offense.” Id. at 169. This is true even where the prior conviction and sentence

are the result of a guilty plea. See id. Thus, in the absence of an exception to 4

the general rule, Brown forbids the defendant’s conviction and sentence for riot

following his guilty plea to disorderly conduct.

There are several recognized exceptions to the general rule prohibiting

successive prosecution for a greater and lesser-included offense. “One

commonly recognized exception is when all the events necessary to the greater

crime have not taken place at the time the prosecution for the lesser is begun.”

Jeffers v. United States, 432 U.S. 137, 151 (1977). A second is where “the facts

necessary to the greater were not discovered despite the exercise of due

diligence before the first trial.” Id. at 152. A third exists where “the defendant

expressly asks for separate trials on the greater and the lesser offenses, or, in

connection with his opposition to trial together, fails to raise the issue that one

offense might be a lesser-included offense of the other.” Id. A fourth exception

was set forth in Ohio v. Johnson, 467 U.S. 493 (1984), State v. Franzen, 495

N.W.2d 714 (Iowa 1993), and State v. Trainer, 762 N.W.2d 155 (Iowa Ct. App.

2008). It is the nature and scope of this fourth exception that is in dispute.

The State interprets Johnson, Franzen, and Trainer to stand for the

proposition that a defendant’s plea of guilty to and conviction of a lesser-included

offense, when the defendant has knowledge that a charge for a greater offense

has been filed, whether set forth in the same charging instrument or a different

charging instrument, does not bar successive prosecution for the greater offense.

The dissent interprets these cases to stand for the proposition that a defendant’s

plea of guilty to and conviction of a lesser-included offense after a charge has

been filed, whether set forth in the same charging instrument or a different

charging instrument, regardless of the defendant’s knowledge of the filed charge, 5

does not bar prosecution for the greater offense. Under the State and the

dissent’s interpretation, the focus of the inquiry is whether the State had filed a

charge for the greater offense prior to the time of plea and conviction. Although

both interpretations are reasonable, we conclude both interpretations ultimately

focus on the wrong issue.

The critical issue in Johnson, Franzen, and Trainer was not that a charge

for the greater offense had been filed at the time of plea and conviction or that

the defendant knew a charge for the greater offense had been filed at the time of

plea and conviction; the critical issue was the defendant’s unilateral deprivation

of the State’s asserted interest in further prosecution through offensive use of the

Double Jeopardy Clause, either over the State’s objection or without the State’s

knowledge.

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Related

Green v. United States
355 U.S. 184 (Supreme Court, 1957)
Benton v. Maryland
395 U.S. 784 (Supreme Court, 1969)
Jeffers v. United States
432 U.S. 137 (Supreme Court, 1977)
Brown v. Ohio
432 U.S. 161 (Supreme Court, 1977)
Ohio v. Johnson
467 U.S. 493 (Supreme Court, 1984)
United States v. Roland Schuster
769 F.2d 337 (Sixth Circuit, 1985)
State v. Iowa District Court for Winneshiek County
464 N.W.2d 233 (Supreme Court of Iowa, 1990)
State v. Trainer
762 N.W.2d 155 (Court of Appeals of Iowa, 2008)
People v. Price
867 N.E.2d 972 (Appellate Court of Illinois, 2006)
State v. Butler
505 N.W.2d 806 (Supreme Court of Iowa, 1993)
State v. Franzen
495 N.W.2d 714 (Supreme Court of Iowa, 1993)
Moore v. State
882 N.E.2d 788 (Indiana Court of Appeals, 2008)
State v. Kameroff
171 P.3d 1160 (Court of Appeals of Alaska, 2007)
State v. Knaff
713 N.E.2d 1112 (Ohio Court of Appeals, 1998)

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