In the Matter of R.M.d, Alleged to Be Seriously Mentally Impaired, R.M.d
15-1434
| Iowa Ct. App. | Oct 12, 2016Background
- R.M.D., serving long prison sentences for sexual abuse, was also civilly committed as "seriously mentally impaired" and ordered to inpatient care; he was housed at the Iowa Medical and Classification Center (IMCC).
- R.M.D. sought to challenge a mental-health commitment order and requested appointment of counsel for a habeas corpus proceeding under Iowa Code § 229.37.
- The district court initially appointed counsel, scheduled a hearing, then counsel questioned whether his public‑defender contract authorized representing R.M.D. in the habeas matter; the hearing was canceled and counsel was directed to recast his motion.
- Counsel filed a "motion for declaratory relief" raising (1) whether R.M.D. had a constitutional right to court‑appointed counsel in a § 229.37 habeas proceeding, (2) whether the public‑defender contract authorized such appointment, and (3) whether R.M.D. was entitled to a state‑funded independent medical examination (IME).
- The State moved to dismiss. The district court dismissed the declaratory motion, citing Iowa Code §§ 822.1 and 229.37, and concluded R.M.D. had no constitutional right to court‑appointed counsel; the court declined to decide the IME issue.
- On appeal the Court of Appeals reviewed whether dismissal was proper and whether R.M.D. fell within § 229.37's protection; it reversed and remanded for an evidentiary habeas hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ripeness / justiciability of declaratory motion | Motion raised real, imminent issues tied to a scheduled habeas hearing; not advisory | Motion sought advisory rulings on hypothetical future habeas issues; not justiciable | Motion was ripe; issues justiciable because habeas had been requested and a hearing had been scheduled then canceled |
| Applicability of Iowa Code § 822.1 (bar on habeas for convicted persons) | § 822.1 does not bar habeas challenging civil commitment orders under § 229.37 | § 822.1 prohibits habeas for persons convicted or sentenced for public offenses | § 822.1 inapplicable; § 229.37 permits habeas for persons confined as seriously mentally impaired |
| Whether R.M.D. was "confined as seriously mentally impaired" under § 229.37 | He was subject to involuntary hospitalization/commitment orders and alternative placement at IMCC, producing confinement beyond criminal incarceration | State argued he was not such a person because he remained an inmate under Department of Corrections | Court held R.M.D. was confined as seriously mentally impaired and entitled to habeas under § 229.37 |
| Right to appointed counsel / IME at State expense | (Raised) claimed entitlement to appointed counsel and to an IME for habeas purposes | State argued no entitlement to court‑appointed counsel in § 229.37 habeas; IME not yet ripe | Court declined to decide counsel and IME issues on appeal (not properly before court); parties may raise them on remand |
Key Cases Cited
- DeVoss v. State, 648 N.W.2d 56 (Iowa 2002) (explains appellate preservation — generally will not consider issues raised first on appeal)
- Taft v. Iowa Dist. Ct., 879 N.W.2d 634 (Iowa 2016) (describes ripeness / present‑controversy requirement and avoidance of advisory opinions)
- In re B.T.G., 784 N.W.2d 792 (Iowa Ct. App. 2010) (treats review of commitment/placement as a § 229.37 habeas petition)
- Hackett v. State, 354 N.W.2d 247 (Iowa Ct. App. 1984) (distinguishes postconviction relief procedures from habeas challenges to civil commitment)
- Maghee v. State, 639 N.W.2d 28 (Iowa 2002) (recognizes court's inherent authority or discretion to appoint counsel pro bono in some habeas contexts)