State of Iowa v. Wonetah Einfeldt, 914 N.W.2d 773

Background

Defendants Wonetah Einfeldt and two daughters were tried jointly for willful injury after a July 14, 2015 beating of victim Mulika Vinson; video and eyewitnesses supported the State's case.
Midtrial Einfeldt’s counsel moved for a competency examination under Iowa Code chapter 812 after Einfeldt exhibited bizarre statements (e.g., wanting to kill/stab counsel, believing counsel was colluding with the State, hearing buzzing, claiming FBI told her she did nothing wrong) and said she had prior diagnoses (paranoid schizophrenia, bipolar, PTSD) but had not taken medication for months.
The district court conducted a brief, out-of-jury colloquy, observed Einfeldt’s courtroom demeanor, reviewed records later (medical records and PSI), and denied a chapter 812 competency evaluation both midtrial and at sentencing; Einfeldt was convicted and sentenced to up to five years.
On appeal the Iowa Supreme Court reviewed de novo whether the court should have ordered a competency hearing and reviewed evidentiary rulings for abuse of discretion.
The court held the trial court abused the statutory/federal due-process standard by denying a competency evaluation given counsel’s credible representation and Einfeldt’s contemporaneous statements and history; conviction reversed and remanded for a new trial.
The court affirmed the exclusion of evidence about the victim’s juvenile-era convictions, threats to a third party, and an unproved shooting incident as more prejudicial than probative under Iowa Rules 5.403 and 5.404.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court erred in refusing a competency exam under Iowa Code §812.3 and due process	Einfeldt: counsel credibly asserted incapacity to assist; contemporaneous delusional statements, prior diagnosis, medication noncompliance and distrust of counsel raised a bona fide doubt requiring evaluation	State/district court: courtroom demeanor and participation showed comprehension; no prior application and observed behavior did not show inability to understand charges or assist counsel	Reversed: de novo review finds probable cause for a competency evaluation; remand for new trial and proper competency procedures
Whether retrospective review cures failure to hold competency hearing	Einfeldt: retrospective records (PSI, medical) plus trial record show doubt at trial time	State: later records insufficient to change ruling; trial observations dispositive	Court: retrospective determination inadequate; failure to order midtrial evaluation warrants new trial
Admissibility of victim’s prior assault convictions (juvenile/young adult)	Einfeldt: convictions relevant to self-defense and victim’s violent character	State: convictions remote in time and occurred when victim was adolescent; prejudicial	Affirmed exclusion: remote juvenile-era convictions more prejudicial than probative under Rules 5.403/5.404
Admissibility of shots-fired incident and threats to third party	Einfeldt: shooting supports her belief Vinson was dangerous; threats show propensity for violence	State: insufficient proof linking Vinson to shooting; threats were verbal and no assault occurred	Affirmed exclusion: insufficient proof and marginal probative value outweighed by prejudice under Rules 5.403/5.404

Key Cases Cited

Pate v. Robinson, 383 U.S. 375 (defendant must be competent to stand trial; conviction of incompetent defendant violates due process)
Dusky v. United States, 362 U.S. 402 (competency standard: ability to consult with counsel with rational understanding and rational/factual understanding of proceedings)
Drope v. Missouri, 420 U.S. 162 (due process requires threshold hearing when sufficient doubt exists; courts must remain alert to changed competence during trial)
Cooper v. Oklahoma, 517 U.S. 348 (state may not impose heightened proof standard for incompetency; comparative consequences favor ordering evaluation)
Ford v. Wainwright, 477 U.S. 399 (procedural mechanism required to determine need for competency evaluation under due process)
Griffin v. Lockhart, 935 F.2d 926 (attorney’s express doubt is a legitimate factor in competency determinations)
Maxwell v. Roe, 606 F.3d 561 (history of mental illness, medication refusal, and courtroom paranoia can create reasonable doubt of competence)