On July 20th, 2012, the Iowa Supreme Court affirmed a ruling by the Iowa District Court in the case of The State of Iowa vs. Mark Becker. Becker was convicted of the 2009 murder of Parkersburg high school football coach Edward Thomas. During the trial, Becker pleaded not guilty by reason of insanity. After he was found guilty by the District Court, he appealed on the grounds that the court refused to instruct the jury on the consequences for finding a person guilty by reason of insanity when they inquired. The district court has sentenced Becker to life in prison without the possibility of parole, which he will now have to serve after the Supreme Court’s ruling.
As detailed in the Iowa Supreme Court opinion: “On June 24, 2009, Mark Becker shot and killed Edward Thomas in a temporary high school weight room in Parkersburg, Iowa, in front of numerous high school students participating in summer workouts.” Becker was described by his mother as “active” and “friendly” as a child though he withdrew into himself as he got older and entered high school. Over the course of high school, college, and his postgraduate years, Becker continued to withdraw, and became more and more depressed. Eventually, he began to have violent episodes, yelling, swearing, and, while living in his parent’s home, “hitting the basement walls with a baseball bat”. At this point he claimed to have a “metaphysical ESP connection with [Edward] Thomas and that Thomas was sending him messages that were keeping him up at night”. Becker was arrested several times for violent behavior and had routinely been committed to short stays at the local hospital’s psychiatric ward. It was there that he was given medication that was supposed to reduce his violent outbursts.
On the morning of June 20th, 2009, Mark Becker had yet another violent episode at the home of a Cedar Falls man, Dwight Rogers, who did not have any relationship with Becker and, in fact, did not even know him. Becker swore at Rogers, saying, “You know who the F I am.” He then became physically violent, taking a baseball bat to Rogers’ front door and two windows before trying to drive his car through Rogers’ garage door. Becker fled the scene when the police arrived, and proceeded to lead them on a high-speed car chase which only ended when he hit a deer with his car. He was again arrested and sent to a psychiatric ward, but this time it was ordered that he be evaluated and law enforcement be notified before his release. After Becker’s evaluation, he was diagnosed with paranoid schizophrenia and given medication for treatment. The hospital discharged him soon after without notifying the police department.
Over the course of the next few days, Becker’s mental state appeared to be improving. He made plans to get his prescription filled and spent the night at his parent’s home. In the supreme court opinion it describes Mark Becker’s mother as having “felt that Becker seemed to be doing better than he had in quite some time”.
On the morning of June 24th, 2009, Mark Becker woke up and had coffee with his father at 4:30 in the morning. His mother joined them at 5:00 AM. After his parents left for work, he broke into the gun cabinet in the basement and took out a .22 caliber revolver. He went outside and started shooting at a birdhouse in his parent’s backyard. According to the supreme court opinion, Becker would later tell police that “after his practice session he knew he would have to get close to Thomas in order to be sure that he hit him.”
After loading more bullets into the gun he took his parent’s car and drove to Aplington, where he asked a local resident where Ed Thomas was. When he was told the resident didn’t know, Becker drove to Parkersburg and asked around for Thomas again under the pretense that he needed to find Thomas “because he [Becker] was working with him on a tornado relief project”. Becker then drove to the elementary school in town, then to the high school when Thomas could not be found at the elementary school. He was told he could find Thomas in the temporary weight room of the high school located in the “bus barn”.
Becker initially left the revolver in his car. He reportedly “stuck his head in the door of the bus barn and looked around and left” before returning with the gun. As detailed in the supreme court opinion, Becker “reentered the weight room, approached Thomas, took out the gun, and shot Thomas six times in the head, chest and leg. He proceeded to kick and stomp on Thomas, yelling, ‘F**k you, old man.’ He then left the weight room screaming that he had killed Satan and telling people to go get his carcass”. Becker drove his parent’s car back to their home and was confronted by police. He cooperated when ordered to drop his weapon and was arrested.
Though he admitted to killing Thomas, Becker pleaded not guilty by reason of insanity, citing his years-long history of mental health problems, up to and including his diagnoses as a paranoid schizophrenic. His defense team called two psychiatrists to the stand who testified that “Becker was suffering from paranoid schizophrenia, and that, as a result, Becker did not know and understand the nature or consequences of his actions and was incapable of distinguishing right from wrong in relation to those actions.”
Under the law, someone can be deemed not guilty of a crime by reason of insanity, if it can be proven that they were legally insane at the moment the crime occurred. A person being diagnosed with a mental disorder, even one as serious as paranoid schizophrenia, does not guarantee a verdict of not guilty by reason of insanity. It can be extremely difficult for a defense to show that the accused was insane at the time, even though the burden of proof is on the prosecution. Because the crime has already been confessed to in cases such as Mark Becker’s, the burden of proof is much easier to bear for the plaintiff as all they have to prove beyond a reasonable doubt is that Becker knew what he was doing was wrong and understood the “nature and consequences of his actions”.
When the trial was handed over to the jury to deliberate and come to a decision for a verdict, they sent a question to the judge asking “what would happen if Becker were found not guilty by reason of insanity,” according to the supreme court opinion. The judge refused to answer their question and instead reminded the jury that their duty was to determine guilt or innocence and they had nothing to do with sentencing or the consequences of their verdict. This refusal to answer the jury’s question, according to Mark Becker, unfairly swayed the jury to convict him rather than declare him legally insane and violated his due process rights.
When a person is declared not guilty of a crime by reason of insanity, they are not set free as is the case in a regular not guilty verdict. The criminally insane are sent to various treatment centers, mental health institutions, and asylums. If the person responds to treatment and shows signs of recovery, they can be released, though there are cases where persons are deemed too dangerous to be re-integrated into society and are locked away permanently.
By saying that the court violated his “due process rights” in not providing the jury with the answer to their question, Becker implied that because the jury was not provided with information regarding the consequences of finding someone not guilty by reason of insanity, they were prejudiced in their decision to convict him. If, perhaps, members of the jury believed that Mark Becker would be set free if found not guilty, they would be more inclined to convict him. Though they could have potentially believed him to be criminally insane and thus not guilty, they could have been worried about placing him back into a free society and so convicted him.
However, the Iowa Supreme Court ruled that not answering the jury’s question did not create undue prejudice in their decision making. Because the judge did not simply refuse to answer, but instead pointed the jury to a specific jury instruction stating that they were not to concern themselves with the punishment given as a result of their verdict, the prejudice was not established. What was described above could still have occurred, but it would not be the responsibility of the judge or the court. If the jury followed the jury instructions and the instruction of the judge, they would not have been considering possible outcomes and punishments Mark Becker would face, and thus would not have let those possibilities influence their verdict. This reasoning is why the supreme court affirmed the decision of the district court, and Mark Becker is still deemed guilty of the murder of Edward Thomas, and will have to fulfil his sentence of life in prison without the possibility of parole.