State of Iowa v. Edward A. Campbell
16-0550
| Iowa Ct. App. | Jun 7, 2017Background
- Defendant Edward Campbell entered an acquaintance’s apartment without permission, struck the occupant, was subdued, then minutes later damaged the acquaintance’s vehicle; arrested and charged with first-degree burglary, second-degree criminal mischief, and assault causing bodily injury (assault merged with burglary).
- Appointed counsel represented Campbell; he filed numerous motions including competency and multiple self-representation requests; the court eventually permitted him to proceed pro se with standby counsel for part of the trial.
- Mid-trial Campbell moved for a competency determination citing missed medication, anxiety, hallucinations, and a prior mental-health history; the court declined to order a psychological exam and continued the trial.
- Campbell was convicted by a jury of first-degree burglary and second-degree criminal mischief; he appealed raising claims about competency to stand trial, competency to self-represent, pretrial denial of self-representation, hearsay admission (repair invoice and owner testimony), and exclusion of witness testimony under a motion in limine.
- The district court denied post-trial competency requests and a motion for mistrial; it admitted the owner’s testimony about repair costs and (erroneously) an invoice but excluded evidence of homelessness/drug-dealing under a motion in limine that Campbell himself filed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency to stand trial | State: court properly presumed competence; no probable cause to order evaluation | Campbell: court should have sua sponte ordered competency hearing and suspended proceedings after mid-trial motion and again before sentencing | Affirmed: district court did not err; behavior and record showed competence and no probable cause for evaluation |
| Competency to represent himself | State: same standard as competence to stand trial; Campbell was competent | Campbell: self-representation requires higher capacity than standing trial; he lacked that capacity | Affirmed: court’s detailed colloquy showed waiver was knowing/intelligent and Campbell competent to self-represent |
| Pre-trial denial/postponement of self-representation | State: court deferred and provided opportunities; no violation | Campbell: court unlawfully delayed or denied his Sixth Amendment right to go pro se before trial | Affirmed: Campbell withdrew requests or impeded colloquies; court did not violate right to self-representation |
| Hearsay admission re: repair costs (invoice & owner testimony) | State: any invoice error was harmless because owner’s admissible testimony duplicated cost evidence | Campbell: invoice and owner testimony were inadmissible hearsay; conviction on mischief requires costs > $1000 | Affirmed: owner had sufficient personal knowledge to testify; invoice admission was erroneous but harmless because testimony supplied same proof |
| Exclusion of testimony (motion in limine re: homelessness/drugs) | State: evidence more prejudicial than probative; prosecutor agreed not to introduce it | Campbell: exclusion limited his defense and strategy | Affirmed: Campbell had filed and prevailed on the motion; exclusion proper under Rule 403 and did not deny constitutional right to present a defense |
Key Cases Cited
- State v. Lyman, 776 N.W.2d 865 (Iowa 2010) (competency to stand trial; presumption of competence and burden on defendant)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (Sixth Amendment right to self-representation and requirement that waiver be knowing and intelligent)
- Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (States may require counsel for defendants who are competent to stand trial but lack capacity to conduct trial proceedings themselves)
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (federal standard for competency to stand trial: consult with counsel and rational/factual understanding)
- Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (competence to plead guilty or waive counsel measured by Dusky standard)
- State v. Rieflin, 558 N.W.2d 149 (Iowa 1997) (history of mental illness alone does not establish incompetence)