State of Iowa v. Mark Daryl Becker, 818 N.W.2d 135

Becker killed Edward Thomas in a makeshift Parkersburg, Iowa weight room during a June 24, 2009 incident, in front of many students.
Becker was charged with first-degree murder and asserted an insanity defense; the jury convicted him of first-degree murder.
Becker was sentenced to life without parole and ordered to pay restitution to Thomas’s estate and to Becker’s counsel and expert-witness fees; appellate relief sought on restitution.
Becker had a long history of mental illness, including paranoid schizophrenia, with multiple prior hospitalizations and episodes of violence preceding the shooting.
Becker was arrested, interviewed, and admitted to shooting Thomas; the trial occurred in February 2010 with extensive psychiatric testimony from both sides.
During deliberations, the jury asked what would happen if Becker were found insane; the court told them post-verdict consequences were for the court, not the jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insanity instruction accuracy	Becker	Becker argued the district court should have given his insanity instruction	Insanity instructions 34-35 upheld; not abuse of discretion; read as a whole they conveyed the law.
Consequence of NGI instruction due process	Becker	Becker claimed due process requires a not guilty by reason of insanity consequence instruction	No due process requirement to give consequence instruction under article I, section 9; court affirmed denial.

State v. Hamann, 285 N.W.2d 180 (Iowa 1979) (defines insanity standard and supports proper instruction framework)
Marin v. State, 788 N.W.2d 827 (Iowa 2010) (jury instructions reviewed as whole; abuse of discretion standard; focus on correctness of law)
State v. Schuler, 774 N.W.2d 294 (Iowa 2009) (insanity instruction standards; model jury instructions sufficient)
State v. Fintel, 689 N.W.2d 95 (Iowa 2004) (instructions not considered separately; must reflect law fairly)
State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (constitutional right to jury instructions; de novo review for constitutional issues)
Shannon v. United States, 512 U.S. 573 (1994) (not required to instruct about consequences of insanity verdict in federal context; informs due process framework)
State v. Cox, 781 N.W.2d 757 (Iowa 2010) (procedural due process analysis for not-guilty-by-insanity; isolation of due process standard)