State of Iowa v. Caesar Charles Davison
20-0950
| Iowa | Apr 15, 2022Background
- On Sept. 10, 2017 Demarcus Chew was shot to death; Caesar Davison participated in a group that confronted Chew and was present when multiple shots were fired.
- Davison was tried and the jury convicted him of assault causing serious injury (Iowa Code § 708.2(4)) and conspiracy to commit a forcible felony (murder) (§§ 706.1, 706.3), but acquitted him of first‑degree murder and lesser homicide offenses that required a finding he caused Chew’s death.
- The State sought and the district court ordered $150,000 restitution under Iowa Code § 910.3B(1), which mandates at least $150,000 when “the offender is convicted of a felony in which the act or acts committed by the offender caused the death of another person.”
- Davison objected, arguing § 910.3B either does not apply unless causing death is an element of the convicted offense, or, alternately, the Sixth Amendment (Apprendi line) requires a jury finding beyond a reasonable doubt that he caused the death.
- The Iowa Supreme Court held § 910.3B can apply even when causing death is not an element of the convicted offense, but concluded the mandatory $150,000 is partly punitive and thus, under Apprendi and its progeny, requires a jury finding of the fact that increased the penalty (that the defendant caused the death).
- The court vacated the $150,000 restitution award and Davison’s sentence (remanding for resentencing because the trial court may have misunderstood probation eligibility).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 910.3B applies only when causing death is an element of the convicted felony | State: § 910.3B applies when the defendant’s felonious acts caused a death even if the crime of conviction doesn’t include causing death as an element | Davison: statute requires causing death to be an element of the convicted offense | Court: statutory text and precedent favor broader reading — § 910.3B may be triggered by the defendant’s felonious acts causing death, not only by an element of the offense |
| Whether the mandatory $150,000 restitution under § 910.3B implicates the Sixth Amendment (Apprendi) | Davison: $150,000 is punitive/determinate and increases punishment, so Apprendi/Southern Union/Alleyne require a jury finding beyond a reasonable doubt that he caused the death | State: restitution is compensatory/substitute for civil recovery (and routinely judicially determined); many courts hold Apprendi does not apply to restitution | Court: § 910.3B restitution has punitive and determinate features (mandatory $150,000 floor); Apprendi line applies to facts that increase minimum/maximum punishment; because no jury found Davison caused the death, the award violated the Sixth Amendment — restitution vacated |
| Whether sentencing court abused discretion by not considering probation | Davison: court mistakenly believed he was ineligible for probation because of a forcible-felony conviction | State: argues the court considered probation and the error was not prejudicial | Court: record indicates possible misunderstanding; vacates sentence and remands for resentencing so court can exercise informed discretion |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (Sixth Amendment requires jury finding of any fact that increases statutory maximum punishment)
- Southern Union Co. v. United States, 567 U.S. 343 (2012) (Apprendi rule applies to criminal fines)
- Alleyne v. United States, 570 U.S. 99 (2013) (facts increasing mandatory minimum must be found by a jury)
- Blakely v. Washington, 542 U.S. 296 (2004) (judge may not inflict punishment the jury’s verdict alone does not allow)
- State v. Izzolena, 609 N.W.2d 541 (Iowa 2000) (§ 910.3B has punitive elements; restitution may be treated as a fine)
- State v. Corwin, 616 N.W.2d 600 (Iowa 2000) (§ 910.3B intended to enhance punishment for crimes resulting in death; Ex Post Facto implications)
- State v. Richardson, 890 N.W.2d 609 (Iowa 2017) (§ 910.3B partly punitive; restitution may be treated as part of sentence for some constitutional analyses)
- United States v. Green, 722 F.3d 1146 (9th Cir. 2013) (federal courts generally held Apprendi does not apply to restitution under federal statutes; restitution viewed as compensatory/indeterminate)