Brandon Joseph Christopher Seim v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedSeptember 18, 2024
Docket23-1383
StatusPublished

This text of Brandon Joseph Christopher Seim v. State of Iowa (Brandon Joseph Christopher Seim v. State of Iowa) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brandon Joseph Christopher Seim v. State of Iowa, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1383 Filed September 18, 2024

BRANDON JOSEPH CHRISTOPHER SEIM, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Wapello County, Crystal S. Cronk,

Judge.

Brandon Seim appeals the denial of his application for postconviction relief.

AFFIRMED.

Denise M. Gonyea of McKelvie Law Office, Grinnell, for appellant.

Brenna Bird, Attorney General, and Bridget A. Chambers (until withdrawal)

and Joseph D. Ferrentino, Assistant Attorneys General, for appellee State.

Considered by Badding, P.J., Sandy, J., and Telleen, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

TELLEEN, Senior Judge.

Brandon Seim appeals the denial of his application for postconviction relief,

arguing the district court wrongly rejected his claim that criminal trial counsel was

ineffective in relation to his guilty plea.

I. Background Facts and Proceedings

In 2011, Seim was charged by trial information with first-degree murder. He

initially pled not guilty. Shortly before trial was scheduled to take place in February

2014, Seim entered a guilty plea to the lesser-included offense of second-degree

murder. At the plea hearing, Seim acknowledged his understanding of the

consequences of his plea and agreed that he had an opportunity to review the

minutes of testimony and that the minutes were accurate.

A few weeks later, Seim filed a letter with the court requesting that his plea

be withdrawn and his privately-retained counsel, Benjamin Bergmann, be removed

from the case. Bergmann then moved to withdraw and asked for appointment of

the special defense unit of the public defender’s office.1 The court granted both

requests and appointed Jason Dunn and Jill Eimermann from the special defense

unit. A hearing on Seim’s request to withdraw his plea was held in April. At that

hearing, Dunn told the court that he and Eimermann advised Seim to “withdraw his

request to take back his plea” and proceed to sentencing, with which Seim agreed.

Seim confirmed his agreement with that advice on the record.

In the coming weeks, however, Seim filed two letters with the court. In the

first, Seim requested that his attorneys be removed from the case and he be

1 The special defense unit had previously represented Seim for a portion of the

proceeding before he retained private counsel. 3

allowed to represent himself. In the second, Seim repeated his request for self-

representation and added that he wanted to “appeal the plea decision.” The court

denied the requests made in the first letter but later ordered that the requests made

in the second letter be addressed at sentencing. At the sentencing hearing, the

court gave Seim an opportunity to elaborate on his second letter. Seim explained

he knew there was enough evidence to convict him but stated he “tend[s] to bounce

between . . . one decision and another” on whether he wants to plead guilty. Once

the court advised Seim he would have appeal rights, however, Seim said he didn’t

want the court to do anything in relation to his letter. When specifically asked

whether he wanted to withdraw his plea, Seim answered in the negative.

Ultimately, Seim was adjudged guilty of second-degree murder and sentenced to

prison.

On direct appeal, Seim argued “his counsel rendered constitutionally

deficient performance by allowing [him] to plead guilty to second-degree murder

without a factual basis supporting the element of ‘malice aforethought.’” State v.

Seim, No. 14-0845, 2015 WL 409220, at *1 (Iowa Ct. App. Jan. 28, 2015). We

found a sufficient factual basis and affirmed. See id.

Seim filed an application for postconviction relief in 2017. Relevant to this

appeal, Seim argued he received ineffective assistance of counsel in relation to

his guilty plea. Specifically, Seim alleged “counsel coerced him into accepting a

plea bargain by threatening a greater sentence because of the felony murder rule,”

which rendered his plea involuntary.

A hearing on the application was held in February 2023. When Bergmann

was asked in his testimony whether Seim was “threatened or coerced into taking 4

the plea,” he answered: “No way.” Bergmann went on to explain he covered all of

the aspects of the plea with Seim—“the factual basis, the waiver of constitutional

rights, the maximum and minimum penalties.” Eimermann testified her and Dunn’s

assessment of the case and evidence after they were reappointed was that Seim

would be convicted of first-degree murder if he proceeded to trial, so their advice

was that he not withdraw his plea to second-degree murder. Eimermann testified

Seim was not coerced into abandoning his motion to withdraw his guilty plea. In

his testimony, Dunn concurred with Eimermann that the facts of the case had ”all

the makings of” murder in the first degree, so “murder two was a good result for

him in this case.” Because Dunn didn’t think it was going to get any better for

Seim, it was his “advice to keep his plea.”

Seim testified he thought he should have been allowed to withdraw his guilty

plea and he had “very little working knowledge of the court system” at the time he

pled guilty. When Seim was asked whether he was “coerced or threatened to take

the plea deal,” he said that Dunn wouldn’t let him see any of the State’s evidence

until he decided whether he was going to plead guilty or proceed to trial. 2 After

being advised that it was in fact Bergmann who was his attorney when he pled

guilty, Seim said Bergmann never pressured him to plead guilty. Seim also agreed

Bergmann provided competent representation. Later, Seim said he agreed with

Dunn and Eimermann’s advice to abandon his motion to withdraw his guilty plea.

Seim testified his goal on postconviction relief was “to get anything less than what

I have now as far as sentencing and time I have to serve goes.” In his post-hearing

2 As noted above, however, Seim had previously agreed at the plea hearing that

he had a chance to review the minutes of testimony. 5

brief, Seim argued that Dunn provided ineffective assistance when he “prevented

[him] from withdrawing his guilty plea.”

The district court ultimately denied postconviction relief, and this appeal

followed.3

II. Standard of Review

Appellate review of the district court’s denial of an application for

postconviction relief alleging ineffective assistance of counsel is de novo. See

Sothman v. State, 967 N.W.2d 521, 522 (Iowa 2021).

III. Discussion

A claim of ineffective assistance of counsel requires proof that (1) counsel

failed to perform an essential duty and (2) prejudice resulted. Strickland v.

Washington, 466 U.S. 668, 687 (1984); State v. Lopez, 907 N.W.2d 112, 116

(Iowa 2018). We “may consider either the prejudice prong or breach of duty first,

and failure to find either one will preclude relief.” State v. McNeal, 897

N.W.2d 697, 703 (Iowa 2017) (citation omitted).

On appeal, Seim argues “trial counsel did not clearly explain to [him] the

consequences of his felony guilty plea”; he did “not understand the consequences

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Carroll
767 N.W.2d 638 (Supreme Court of Iowa, 2009)
Arnold v. State
540 N.W.2d 243 (Supreme Court of Iowa, 1995)
State of Iowa v. Christopher Clay McNeal
897 N.W.2d 697 (Supreme Court of Iowa, 2017)

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