State of Iowa v. Jodie Sherman
16-0705
| Iowa Ct. App. | Jun 7, 2017Background
- On July 4, 2014, Jodie Sherman stabbed Douglas Richt in his car; Richt died from a neck stab wound. A bloody 12-inch knife was found in the car; blood matched Richt. Sherman made post-incident statements about being kidnapped and exhibited bizarre behavior.
- Police detained Sherman shortly after the stabbing; she complained of kidnapping, requested an attorney during a brief recorded interview, and was later charged with first‑degree murder.
- Mental-health evaluations diagnosed psychosis/schizophrenia spectrum symptoms and other disorders; Sherman was initially found incompetent, sent for restoration, and later found competent to stand trial.
- At her bench trial (jury waived) Sherman admitted the stabbing but asserted an insanity defense under Iowa Code § 701.4, bearing the burden to prove insanity by a preponderance of the evidence.
- Competing expert testimony: Dr. Paul (defense) opined Sherman was delusional and lacked capacity to know the nature/quality of her act or distinguish right from wrong; Dr. Moore (State) agreed Sherman had hallucinations but could still understand her conduct.
- The trial court found Sherman guilty of second‑degree murder (malice implied from use of a deadly weapon), rejected the insanity defense, denied a motion for new trial and arrest of judgment, and Sherman appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports conviction of second‑degree murder (sufficiency / weight of evidence) | State: Evidence (knife, conduct, post‑event statements, witness observations) shows intentional stabbing and malice; verdict supported by weight of evidence | Sherman: Bizarre behavior and mental illness undermine mens rea and warrant reversal or new trial | Court: Affirmed — evidence and witness observations support second‑degree murder; verdict sustained under both sufficiency and weight‑of‑evidence standards |
| Whether Sherman proved insanity by a preponderance of evidence (affirmative defense) | State: Defense experts did not persuade court; observed volitional, purposeful acts show knowledge of wrongfulness | Sherman: Expert testimony and history of psychosis show she was incapable of knowing nature/quality or distinguishing right from wrong | Court: Affirmed — trial court found defense failed to meet burden; acts (escaping scene, following commands, advising officers) indicated awareness of wrongfulness |
Key Cases Cited
- State v. James, 393 N.W.2d 465 (Iowa 1986) (defendant bears burden to prove insanity by preponderance)
- State v. Reeves, 636 N.W.2d 22 (Iowa 2001) (malice may be implied from intentional use of a deadly weapon)
- Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issue preservation requires raising issue and trial court ruling)
- State v. Leckington, 713 N.W.2d 208 (Iowa 2006) (review standards for motion in arrest of judgment)
- State v. Ellis, 578 N.W.2d 655 (Iowa 1998) (weight‑of‑evidence standard and trial court discretion on new trials)