Background
Tramontez Lockett helped arrange a meeting with Michael McCune after members of Lockett’s group planned to kill McCune. Using a phone and Snapchat messages, Lockett drew McCune from his apartment building. Two codefendants then shot and killed McCune, and Lockett drove the group away. Lockett was not a shooter.
After being charged as an aider and abettor, Lockett entered an Alford plea to second-degree murder and pleaded to other offenses. The district court sentenced him to fifty years for murder and ordered him to pay $150,000 to McCune’s heirs under Iowa Code section 910.3B. Lockett appealed the statutory restitution award, arguing that no factfinder had determined that he caused McCune’s death.
The Court’s Holding
The Iowa Court of Appeals affirmed. Lockett could challenge the restitution order on direct appeal because it was part of his sentence, rather than an attack on the validity of his plea.
On the merits, the court held that the restitution award complied with the Sixth Amendment and section 910.3B. Causing another person’s death is an element of second-degree murder, and an aider and abettor is charged, tried, and punished as a principal under Iowa law. Thus, Lockett’s conviction for aiding and abetting second-degree murder necessarily established the causation finding required for the death-based restitution award. His Alford plea did not change that result because it required a factual basis supporting every element of the offense.
Key Takeaways
- A section 910.3B restitution award may be imposed when a homicide conviction necessarily includes causation of the victim’s death.
- An aider and abettor of second-degree murder is treated as a principal for purposes of the death-causing element.
- An Alford plea does not avoid an element established by the factual basis for the offense.
Why It Matters
The decision distinguishes State v. Davison, where the defendant’s convictions did not require a finding that he caused a death. For homicide convictions, including aiding-and-abetting convictions, the required causation finding is inherent in the offense and supports Iowa’s statutory $150,000 restitution assessment.