Carloss Robinson v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedAugust 4, 2021
Docket19-1242
StatusPublished

This text of Carloss Robinson v. State of Iowa (Carloss Robinson 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
Carloss Robinson v. State of Iowa, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 19-1242 Filed August 4, 2021

CARLOSS ROBINSON, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Linn County, Lars Anderson, Judge.

Carloss Robinson appeals from the denial of his postconviction relief (PCR)

application. AFFIRMED.

Webb L. Wassmer of Wassmer Law Office, PLC, Marion, for appellant.

Thomas J. Miller, Attorney General, and Timothy M. Hau, Assistant Attorney

General, for appellee State.

Heard by Doyle, P.J., and Mullins and May, JJ. 2

DOYLE, Presiding Judge.

Carloss Robinson appeals from the denial of his postconviction relief (PCR)

application. He argues the PCR court erred in rejecting his prosecutorial

misconduct argument, erred in denying his ineffective-assistance-of-counsel claim

about evidence of his praying during a police interrogation, and erred in denying

his request for a DNA sample. We affirm the PCR court’s ruling.

I. Background Facts and Proceedings.

A jury found Robinson guilty of first-degree murder in 2002. He was

sentenced to life in prison. Robinson appealed. This court affirmed his conviction.

State v. Robinson, No. 02-767, 2003 WL 21459681, at *10 (Iowa Ct. App. June 25,

2003). In October 2003, Robinson filed a pro se PCR application, and he was

appointed counsel. His lawsuit simmered on the court’s backburner for almost

fourteen years before it came to trial in August 2017. In the interim, Robinson filed

multiple and long pro se amendments to his application. A seemingly endless

string of motions to continue were granted. The PCR court ruled in April 2019 that

Robinson had no right to relief. After his post-trial motion was denied, Robinson

appealed. The appeal was transferred to this court in April 2021.

II. Scope of Review.

“We normally review postconviction proceedings for errors at law.” Castro

v. State, 795 N.W.2d 789, 792 (Iowa 2011). But when there are ineffective-

assistance-of-counsel claims, our review is de novo. Id.

III. Analysis.

Robinson raises three issues on appeal. First, he contends the prosecutor’s

closing argument comments that Robinson’s trial testimony was “ludicrous,” 3

“ridiculous,” and “bogus” were improper and prejudicial. Second, he argues his

trial counsel provided ineffective assistance in failing to object to State’s evidence

regarding “prayer” by Robinson during his police interview. Third, he contends the

PCR court misconstrued Iowa Code section 81.8(5) (2019) in denying Robinson’s

request for a DNA sample.

A. Prosecutor’s Closing Argument.

During closing arguments, the prosecutor characterized Robinson’s trial

testimony as “ludicrous,” “ridiculous,” and “bogus.” Robinson argues those words

“violated the requirements of State v. Graves, 668 N.W.2d 860 (Iowa 2003), which

prohibits a prosecutor from calling a witness a liar or using similar language.”

Robinson’s counsel did not object to the prosecutor’s comments during trial, nor

was the issue raised on direct appeal. Robinson first raised the Graves issue in

his amended PCR application, and also raised it as one of ineffective assistance

of counsel. The PCR court addressed the merits of the prosecutorial misconduct

issue and found there was misconduct but no resulting prejudice.

In determining there was prosecutorial misconduct, the PCR court stated:

Robinson’s PCR counsel cites to State v. Graves as setting forth the appropriate legal standard to determine whether there was prosecutorial misconduct and resulting prejudice. While Graves was decided after Robinson’s criminal trial, I have no problem applying Graves to Robinson’s case. In Graves, the court noted “just two years prior to the trial in this matter, this court held that comments similar to those made by the county attorney in this case were ‘clearly improper.’” State v. Graves, 668 N.W.2d 860, 882 (Iowa 2003) (citing State v. Rutledge 600 N.W.2d 324, 325 (Iowa 1999)). In Graves the court stated that “[i]t is improper for a prosecutor to call the defendant a liar, to state the defendant is lying, or to make similar disparaging remarks.” Id. at 876. “Notwithstanding this prohibition, a prosecutor is still free ‘to craft an argument that includes reasonable inferences based on the evidence and . . . when a case turns on which of two conflicting stories is true, [to argue that] 4

certain testimony is not believable.’” Id. (quoting State v. Davis, 275 Kan. 107, 61 P.3d 701, 710–11 (2003)). It is only misconduct “when the prosecutor seeks [to tarnish the defendant’s credibility] through unnecessary and overinflammatory means that go outside the record or threaten to improperly incite the passions of the jury. State v. Carey, 709 N.W.2d 547, 556 (Iowa 2006).” To determine whether the line between zealous advocacy and misconduct has been crossed, courts are to consider three factors: (1) Could one legitimately infer from the evidence that the defendant lied? (2) Were the prosecutor’s statements that the defendant lied conveyed to the jury as the prosecutor’s personal opinion of the defendant’s credibility, or was such argument related to specific evidence that tended to show the defendant had been untruthful? And (3) Was the argument made in a professional manner, or did it unfairly disparage the defendant and tend to cause the jury to decide the case based on emotion rather than upon a dispassionate review of the evidence? Graves, 668 N.W.2d at 874–75. Applying these factors to the objected to statements, I find that that line was crossed with the statements involving the words ludicrous, ridiculous, and bogus. Robinson admitted that he lied to the police. Including his trial testimony, he gave three different versions about what happened. Some of the objected to statements by the prosecutor were permissible comments on Robinson’s credibility. The ludicrous, ridiculous, and bogus statements, however, were statements that were unduly disparaging and risked creating an emotional reaction. They crossed the line.

The PCR court continued its analysis, weighing all the Graves prejudice

factors together, and concluded Robinson did not establish that he was prejudiced

by the statements at issue:

First, the conduct at issue was neither severe nor pervasive. The statements, while crossing the line, were made as part of an otherwise permissible argument. The prosecutor never used the word liar. The words used were inflammatory by a matter of degree. There are five statements in all that are at issue, all grouped closely together. In the context of a multi-day trial and 2000 plus page transcript, the statements are limited. Second, the statements all relate to Robinson’s credibility. Clearly, that was an important issue at trial. However, Robinson’s credibility would have been at issue regardless of the statements. 5

The limited statements at issue were not themselves significant on the issue of credibility when compared to the record as whole.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Osborn v. State
573 N.W.2d 917 (Supreme Court of Iowa, 1998)
State v. Rutledge
600 N.W.2d 324 (Supreme Court of Iowa, 1999)
Ledezma v. State
626 N.W.2d 134 (Supreme Court of Iowa, 2001)
State v. Graves
668 N.W.2d 860 (Supreme Court of Iowa, 2003)
State v. Cox
781 N.W.2d 757 (Supreme Court of Iowa, 2010)
Jones v. State
545 N.W.2d 313 (Supreme Court of Iowa, 1996)
EnviroGas, L.P. v. Cedar Rapids/Linn County Solid Waste Agency
641 N.W.2d 776 (Supreme Court of Iowa, 2002)
State v. Carey
709 N.W.2d 547 (Supreme Court of Iowa, 2006)
Soo Line Railroad v. Iowa Department of Transportation
521 N.W.2d 685 (Supreme Court of Iowa, 1994)
State v. Taylor
596 N.W.2d 55 (Supreme Court of Iowa, 1999)
State v. Taylor
689 N.W.2d 116 (Supreme Court of Iowa, 2004)
State v. Braggs
784 N.W.2d 31 (Supreme Court of Iowa, 2010)
State v. Davis
61 P.3d 701 (Supreme Court of Kansas, 2003)
State of Iowa v. Ricky Lee Putman
848 N.W.2d 1 (Supreme Court of Iowa, 2014)
State of Iowa v. Kevin Deshay Ambrose
861 N.W.2d 550 (Supreme Court of Iowa, 2015)
Eric Wayne Dempsey v. State of Iowa
860 N.W.2d 860 (Supreme Court of Iowa, 2015)
State of Iowa v. Kelvin Plain Sr.
898 N.W.2d 801 (Supreme Court of Iowa, 2017)
Mark Angelo Castro v. State of Iowa
795 N.W.2d 789 (Supreme Court of Iowa, 2011)
State Of Iowa Vs. Calvin Clarence Nelson, Jr.
791 N.W.2d 414 (Supreme Court of Iowa, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Carloss Robinson v. State of Iowa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carloss-robinson-v-state-of-iowa-iowactapp-2021.