Resistance RE Motion To Revert To Juvenile Court

E-FILED 2021 DEC 23 1:28 PM JEFFERSON - CLERK OF DISTRICT COURT
IN THE DISTRICT COURT OF IOWA IN AND FOR JEFFERSON COUNTY
STATE OF IOWA, CRIMINAL NO. FECR005144

Plaintiff
vs.
JEREMY EVERETT GOODALE RESISTANCE TO DEFENDANT’S

Defendant. MOTION TO TRANSFER
JURISDICTION
COMES NOW the State of Iowa through Jefferson County Attorney Chauncey T.
Moulding and does resist Defendant’s Motion to Transfer Jurisdiction to Juvenile Court.
In support thereof, the State notes as follows:
1. Defendant is charged with Murder in the 1st Degree, a Class A felony, and
Conspiracy to Commit a Forcible Felony by Planning or Commission (the
predicate forcible felony being the aforementioned 1st degree murder), a Class
C felony.
2. Defendant was 16 years old at the time of the offense.
3. Murder in the First Degree is a forcible felony under Iowa Code 702.11(1).
Forcible felonies alleged to have been committed by juveniles 16 years of age
or older at the time of the offense are excluded from the jurisdiction of the
Juvenile Court unless good cause is shown, as set forth in Iowa Code
232.8(1)(c). As such, the Defendant was subject to initial, direct jurisdiction of
the District Court for prosecution as an adult.
4. The District Court may transfer a matter to the jurisdiction of the Juvenile Court
when good cause warrants the transfer. State v. Terry, 569 N.W.2d 364 (Iowa
1997). The burden is on the Defendant to show the good cause. See id.
5. When determining the appropriateness of the transfer of jurisdiction to Juvenile
Court, the District Court considers the following: (1) The nature and
circumstance of the alleged delinquent act; (2) The nature and extent of the
child’s prior contacts with juvenile authorities; (3) The programs, facilities, and
personnel available to the Juvenile Court and adult court for rehabilitation and
treatment of the child. See Iowa Code 232.45(8).

6. The State will concede that Mr. Goodale has had limited prior contacts with
juvenile authorities under factor (2) above. However, regarding factor (1), the
Defendant is accused a pre-planned and pre-meditated homicide, an act which
included surveilling the victim’s pattern of life, ambushing her along her daily
walk and dragging her into the woods, then returning later to better hide her
lifeless body. The nature and circumstances are of the alleged criminal act are
as serious as exist under the Iowa criminal code, making the District Court the
only appropriate forum. Regarding factor (3), this prosecuting attorney cannot
fathom any combination of programming at any Iowa juvenile facility which
could appropriately treat or rehabilitate the Defendant if adjudicated as a
juvenile, as discussed below.
7. The State does not believe there are reasonable prospects for rehabilitating the
Defendant in the Juvenile Court System when the above factors are considered.
First, the State argues that there could be no reasonable prospect of
rehabilitating a premeditated murderer in less than 24 months, before the
Defendant turns eighteen. Second, if the 16-year-old Defendant is processed
under the Juvenile Court System and adjudicated on a charge of murder in the
first degree, the adjudicating court would lose jurisdiction over the Defendant
at eighteen, and justice would not be done. Such an outcome would be outside
the interests of the juvenile and the community at large. Third, the District
Court has programs and services available to the Defendant before and after
the age of eighteen. The State believes that the service available to the District
Court for rehabilitation and treatment can better serve the best interest of the
Defendant and the community. See Iowa Code 232.45(6)(c).
8. Pursuant to Iowa Code 803.6, the State does not resist a report being ordered
from a Juvenile Court Officer on whether this Defendant should be transferred
to the Juvenile Court system, which is a statutory entitlement.
9. The State reserves the right to amend and supplement this resistance following
the production of said report from a Juvenile Courts Officer.
WHEREFORE, the State resists transferring the above captioned matter to Juvenile
Court and prays the matter remains in District Court, for the reasons set forth above.
STATE OF IOWA
/s/ Chauncey Mouding

Chauncey T. Moulding
Jefferson County Attorney
51 W Hempstead
Fairfield IA 52556
Phone: (641) 472-9201
Email: [email protected]

Resistance RE Motion To Revert To Juvenile Court

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E-FILED 2021 DEC 23 1:28 PM JEFFERSON - CLERK OF DISTRICT COURT

IN THE DISTRICT COURT OF IOWA IN AND FOR JEFFERSON COUNTY

STATE OF IOWA, CRIMINAL NO. FECR005144

JEREMY EVERETT GOODALE RESISTANCE TO DEFENDANT’S

treatment of the child. See Iowa Code 232.45(8).

/s/ Chauncey Mouding

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