State v. Fetters
562 N.W.2d 770, 1997 Iowa App. LEXIS 14, 1997 WL 229196 (1997)
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Rule of Law:
To establish a prima facie Sixth Amendment violation for lack of a fair cross-section in a jury venire, a defendant must not only show that a distinctive group is underrepresented, but must also prove that this underrepresentation is due to a systematic exclusion inherent in the state's jury-selection process.
Facts:
- Kristina Joy Fetters, a fifteen-year-old resident of a youth treatment facility, began planning to run away and kill her seventy-three-year-old great aunt, Arlene Klehm.
- Fetters confided in fellow residents, including Tisha Versendaal, that she intended to kill Klehm by stabbing her and cutting her throat in order to steal her money and truck.
- Accompanied by her suite mate, Jeanie Fox, Fetters eloped from the facility, obtained a paring knife from a friend's home, and proceeded to Klehm's residence.
- After being let into the home, Fetters attacked Klehm from behind, first striking her with a kettle and a frying pan.
- Fetters then used the paring knife to try and slit Klehm's throat before retrieving a larger kitchen knife and fatally stabbing her in the back.
- During the attack, Fetters prevented Klehm from reaching a telephone to call for help.
- After the murder, Fetters changed out of her bloody clothes, took some necklaces, and searched for keys to a safe and truck before fleeing the scene with Fox.
Procedural Posture:
- Jurisdiction over Kristina Joy Fetters was transferred from juvenile court to the Iowa District Court for Polk County.
- The State of Iowa charged Fetters with first-degree murder.
- At trial, Fetters asserted the defenses of insanity and diminished capacity.
- A jury found Fetters guilty of first-degree murder.
- The trial court denied Fetters's post-trial motions for judgment of acquittal.
- The district court sentenced Fetters to life imprisonment.
- Fetters, as appellant, appealed the judgment and sentence to the Court of Appeals of Iowa.
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Issue:
Does a jury venire composed entirely of Caucasians violate a biracial defendant's Sixth Amendment right to a jury drawn from a fair cross-section of the community when the defendant presents no evidence that the jury selection process itself systematically excludes minorities?
Opinions:
Majority - Habhab, Chief Judge
No, the composition of the jury venire did not violate the defendant's Sixth Amendment right. To establish a prima facie violation of the fair cross-section requirement under the Duren v. Missouri test, a defendant must show (1) the excluded group is distinctive, (2) the group's representation in venires is not fair and reasonable, and (3) this underrepresentation is due to systematic exclusion in the jury-selection process. While Fetters may have satisfied the first two prongs, she completely failed to meet the third, as she presented no evidence regarding the specific procedures used in Polk County to select jurors or any statistical proof that the process itself was inherently exclusionary. The court also affirmed the other trial court decisions, finding substantial evidence to support the jury's rejection of the insanity defense, correctly refusing to instruct the jury on the consequences of an insanity verdict, and properly admitting graphic autopsy photos that were relevant to show malice.
Analysis:
This decision reinforces the significant evidentiary burden placed on defendants challenging the composition of a jury venire under the Sixth Amendment. It clarifies that a defendant cannot establish a constitutional violation merely by pointing to a statistical disparity in a single jury panel. The ruling solidifies the precedent that a successful 'fair cross-section' challenge requires specific proof that the jury selection system itself is fundamentally flawed, making such claims difficult to prove without extensive pre-trial investigation into a jurisdiction's selection procedures.
