## Facts

- Kristina Joy Fetters, a juvenile resident at a Des Moines residential treatment facility, discussed running away and killing her 73-year-old great-aunt, Arlene Klehm, including statements about cutting her throat and robbing her.
- Fetters and another resident left the facility, went to Klehm’s home, waited for visitors to leave, and entered when Klehm let them in.
- In the kitchen, Fetters struck Klehm with a frying pan, attempted to cut her throat, obtained a larger knife, and stabbed Klehm in the back.
- After the killing, Fetters searched for a safe and truck keys; the girls left and later contacted police. Fetters admitted killing Klehm.
- The State charged Fetters with first-degree murder based on premeditation and, alternatively, felony murder during robbery.
- The case was transferred from juvenile court to district court; Fetters asserted insanity and diminished capacity at trial.
- A jury convicted Fetters of first-degree murder, and the court imposed a life sentence.

## Issues

1. Whether substantial evidence supported first-degree murder (premeditation/malice and/or felony murder during robbery) despite insanity and diminished capacity defenses.
2. Whether the court erred by refusing to instruct the jury on the consequences of a verdict of not guilty by reason of insanity or diminished capacity.
3. Whether the jury-selection process violated the Sixth Amendment fair-cross-section requirement.
4. Whether admitting color autopsy photographs was an abuse of discretion due to unfair prejudice.

## Decision

- Affirmed the conviction and life sentence.
- Held substantial evidence supported first-degree murder based on advance statements, planning, and the manner of killing, allowing the jury to find the required mental state and reject asserted defenses.
- Held the trial court properly refused an instruction describing post-verdict consequences of insanity or diminished-capacity outcomes.
- Held no fair-cross-section violation was shown because Fetters did not establish systematic exclusion of a distinctive group.
- Held the admission of color autopsy photographs was within the trial court’s discretion because their probative value was not substantially outweighed by unfair prejudice.

## Legal Principles

- Sufficiency review considers the entire record in the light most favorable to the verdict; substantial evidence is evidence that could convince a rational factfinder of guilt beyond a reasonable doubt, with credibility and weight for the jury.
- Premeditation and malice may be inferred from prior statements of intent, planning activity, manner of killing, and post-offense conduct consistent with the charged theory, including robbery-related acts.
- Juries generally are not instructed on post-verdict consequences (including insanity-related dispositions) because the jury’s role is to decide guilt and applicable defenses under the evidence and law, not punishment or later confinement outcomes.
- A fair-cross-section claim requires proof that (1) a distinctive group was excluded, (2) representation in venires was unfair and unreasonable relative to the community, and (3) the underrepresentation resulted from systematic exclusion; the makeup of a single jury is insufficient.
- Relevant photographs, including autopsy images, may be admitted if probative value is not substantially outweighed by unfair prejudice; admission is reviewed for abuse of discretion.

## Conclusion

The court affirmed Fetters’s first-degree murder conviction, finding sufficient evidence of the required mental state (and an alternative felony-murder basis), no entitlement to instructions on insanity-verdict consequences, no showing of systematic jury underrepresentation, and no evidentiary abuse in admitting relevant autopsy photographs.


State v. Fetters, 562 N.W.2d 770 (Iowa Ct. App. 1997)