State of Iowa v. Ericka Lynn Rankins ( 2024 )

IN THE COURT OF APPEALS OF IOWA
No. 23-1906
Filed November 13, 2024
STATE OF IOWA,
Plaintiff-Appellee,
vs.
ERICKA LYNN RANKINS,
Defendant-Appellant.
________________________________________________________________
Appeal from the Iowa District Court for Polk County, Lawrence P. McLellan,
Judge.
A defendant appeals her prison sentence for three counts of neglect of a
dependent person and six counts of child endangerment. AFFIRMED.
Jessica Donels of Parrish Kruidenier, L.L.P., Des Moines, for appellant.
Brenna Bird, Attorney General, and Nicholas E. Siefert, Assistant Attorney
General, for appellee State.
Considered by Tabor, C.J., and Chicchelly and Sandy, JJ.
2
TABOR, Chief Judge.
Following the death of her five-year-old son, Ericka Rankins pleaded guilty
to six misdemeanor counts of child endangerment and three felony counts of
neglect of a dependent person. For those nine offenses, the district court
sentenced her to a prison term not to exceed thirty-two years. She appeals that
sentence, contending that probation was a better option given her history of trauma
and mental-health struggles. Because the district court did not abuse its discretion
in choosing incarceration based on the “separate and serious nature of each of the
offenses,” we affirm the sentence.1
I. Facts and Prior Proceedings
Rankins committed these crimes in 2020. We start with the most harrowing
offense. On December 19, Rankins left her hotel desk job just before midnight.
On her way home, she picked up pizza for her children—ages two, four, five,
seven, nine, and eleven—whom she left alone while working. She gave food to
the children but did not eat with them. Instead, she took pizza into her bedroom.
One of the children soon alerted her that five-year-old J.R. was in the bathroom
vomiting. When she checked on J.R., she found that he had also defecated in his
pants. She told him to “clean it up” on his own and returned to her bedroom to
rest. Later, while Rankins was sleeping, one of the children came into her
bedroom, alarmed that J.R. had fallen. Rankins got up and went into the bathroom,
1 We review sentencing decisions for the correction of legal error. State v.
McCollaugh, 5 N.W.3d 620, 627 (Iowa 2024). If a sentence falls within statutory
limits, we will not overturn it unless the court abused its discretion or considered
inappropriate matters. Id. We will not find an abuse of discretion unless we can
tell that the court’s reasoning was “clearly untenable.” State v. Formaro, 638
N.W.2d 720, 724 (Iowa 2002).
3
where she found J.R. in the bathtub; he was not moving or breathing. She called
911, and the dispatcher told her how to perform CPR until the paramedics arrived.2
But the child was pronounced dead at the hospital.
The medical examiner found that J.R. had scars on his face, forehead, legs,
buttocks, abdomen, and elbow—in various stages of healing. He explained that
“some of the marks were consistent with blunt force injuries where [J.R.] could
have been hit with a hanger or a belt. Other injuries were consistent with being
burned by cigarettes.”3 A police investigation showed that the child’s father lived
with the family from April through November 2020. Rankins later admitted that she
had not intervened when the father inflicted excessive discipline on the child.
A warranted search of Rankins’s cellphone also revealed videos of three
incidents in 2020 when she disciplined J.R. by forcing him to do “wall sits”—
squatting against a wall with his arms outstretched for up to an hour. According to
investigators, “[w]hen he cried, she hit him.” And in one video—posted on
Facebook—Rankins ridiculed J.R. for peeing his pants at a birthday party.
After J.R.’s death, Rankins avoided investigators. Law enforcement could
not locate her for over two years.4 Then, in February 2023, the State filed a twelve-
count trial information, charging her with seven counts of aggravated-
misdemeanor child endangerment, in violation of Iowa Code sections 726.6(1)(a)
2 At the plea hearing, Rankins stated that she fell asleep at “probably 1:30, 2:00.”
She was “not for sure” how long she was asleep before she found J.R. in the
bathtub. She called 911 around 6:00 in the morning.
3 The medical examiner ruled the cause of J.R.’s death as “undetermined.”
4 Rankins was on probation at the time of the offenses and failed to keep contact
with her probation officer. United States Marshals eventually located her in
Minnesota.
4
and 726.6(8) (2020); one count of child endangerment causing bodily injury, a
class “D” felony, in violation of sections 726.6(1)(a) and 726.6(7); and one count
of child endangerment causing serious injury, a class “C” felony, in violation of
section 726.6(1). The State also charged her with three counts of neglect of a
dependent person, class “C” felonies, in violation of section 726.3.
In September 2023, Rankins reached a plea agreement with the State. She
agreed to plead guilty to six aggravated misdemeanor counts of child
endangerment for creating a substantial risk to the physical, mental, and emotional
health of her six children on December 19 and 20. The parties agreed to jointly
recommend that the sentences for those counts be run concurrently for a term not
to exceed two years. Rankins also pleaded guilty to three class “C” felony counts
of neglect of a dependent person for knowingly exposing J.R. to danger during
incidents in April through December 2020. The State was free to recommend that
those ten-year felony sentences be run consecutively for a total maximum
sentence of thirty-two years.
At sentencing, the defense presented testimony from psychologist Carlo
Giacomoni, who evaluated Rankins to assess how her history of trauma and
depression contributed to the charges against her. Dr. Giacomoni observed that
Rankins had received “similar discipline” as a child so it did not “seem as
problematic” to her. He also noted that she was dealing with the stress of the
children being home from school during the pandemic and was pregnant again,
which added to her fatigue.
In her allocution, Rankins admitted making “some mistakes” but insisted
that she had learned from her actions and asked for probation. In recommending
5
imprisonment, the State stressed the brutality of Rankins’s conduct toward J.R:
“She disparaged him. She hit him. She did everything to make his discipline over
the top, embarrassing, and cruel, and she filmed it because she’s so proud of it.”
The district court adopted the State’s recommendation, imposing a prison
sentence not to exceed thirty-two years. Rankins appeals.5
II. Analysis
Before imposing the sentence, the district court explained that it had
weighed all the relevant information, including the presentence investigation report
(which recommended incarceration) and Dr. Giacomoni’s testimony (he
recommended probation). The court also considered Rankins’s prior convictions,
her age, her family circumstances, and her mental-health history. See Iowa Code
§ 907.5(1). And the court highlighted the serious nature of the offenses. After
reflecting on all those factors, the court decided that the prison sentence
recommended by the State provided “the maximum opportunity for rehabilitation
of Ms. Rankins and the protection of the community from further offenses by her.”
See Iowa Code § 901.5.
On appeal, Rankins acknowledges that the court considered proper factors
but ventures that it weighed them “in an unreasonable or untenable manner.” She
contends that she “did not commit these offenses because she was a mean or
malicious person.” Rather, in her view, she lacked the financial and mental
resources “to supervise or discipline [her children] appropriately.”
5 Rankins satisfied the good-cause requirement in Iowa Code
section 814.6(1)(a)(3). See State v. Damme, 944 N.W.2d 98, 104–05 (Iowa 2020).
6
“[O]ur task on appeal is not to second guess the decision made by the
district court, but to determine if it was unreasonable or based on untenable
grounds.” Formaro, 638 N.W.2d at 725. We find nothing irrational in the district
court’s exercise of sentencing discretion. The court could have placed greater
stock in the opinions offered by Dr. Giacomoni. But it was also free to find that
Rankins’s pattern of neglect and cruelty called for incarceration. We give
sentencing courts wide latitude in deciding among viable options. See State v.
Pappas, 337 N.W.2d 490, 493 (Iowa 1983) (noting that trial courts hold “an
awesome and lonely responsibility in sentencing”). We decline to remand for
resentencing.
AFFIRMED.