Christopher Lee King v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedDecember 6, 2023
Docket22-1370
StatusPublished

This text of Christopher Lee King v. State of Iowa (Christopher Lee King 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
Christopher Lee King v. State of Iowa, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-1370 Filed December 6, 2023

CHRISTOPHER LEE KING, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Des Moines County, John M. Wright,

Judge.

Christopher King appeals the denial of his application for postconviction

relief. AFFIRMED.

Alfredo Parrish and Jessica Donels of Parrish, Kruidenier, Dunn, Gentry,

Brown, Bergmann & Messamer, L.L.P., Des Moines, for appellant.

Brenna Bird, Attorney General, and Kyle Hanson (until withdrawal) and

Sheryl Soich, Assistant Attorneys General, for appellee State.

Heard by Tabor, P.J., Badding, J., and Gamble, S.J.*

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

(2023). 2

BADDING, Judge.

Christopher King, a former city council member turned photographer, was

convicted by a jury of sex crimes against four of his teenage clients.1 We affirmed

his convictions on direct appeal, preserving a narrow ineffective-assistance-of-

counsel claim for postconviction relief. See State v. King, No. 16-1615, 2017

WL 6039990, at *1, *6 (Iowa Ct. App. Dec. 6, 2017). King pursued that relief, which

the district court denied on exhibits and briefing from the parties.

On appeal from the denial of his application for postconviction relief, King

contends the court erred in rejecting his claims that trial counsel was ineffective

for (1) failing to renew a motion for change of venue; (2) failing “to preserve error

when his motion[s] to strike problematic jurors were wrongly denied,”

and (3) eliciting inadmissible vouching testimony.2

To succeed with these claims, which we review de novo, King had to

show (1) deficient performance and (2) prejudice. See Strickland v.

Washington, 466 U.S. 668, 687 (1984); Sothman v. State, 967 N.W.2d 512, 522

(Iowa 2021). 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). “Our ultimate concern is with ‘the fundamental

fairness of the proceeding whose result is being challenged.’” State v. Risdal, 404

N.W.2d 130, 141 (Iowa 1987) (quoting Strickland, 466 U.S. at 696).

1 The jury found King guilty of two counts of sex abuse in the third degree, a lesser

offense of assault with intent to commit sexual abuse, and penetration of genitalia with an object. He was acquitted of dissemination and exhibition of obscene material to a minor and indecent exposure. 2 The only claim raised on direct appeal was the vouching claim, which is the one

that we preserved for postconviction relief. King, 2017 WL 6039990, at *6. 3

I. Venue

In the wake of his arrest in May 2015, newspaper headlines in King’s

hometown read: “Former city councilman faces sex charges,” “Court papers: King

admits to molesting girls,” and “Molestation inquiry expands to adjoining states.”

As the media reports continued, King moved to change venue in July, arguing “that

public condemnation . . . has reached a fever pitch,” with misleading information

from these outlets saturating the county. The State resisted, and a hearing was

held in August. The district court denied the motion for change of venue,

concluding “the nature, tone, and accuracy of the articles” and their timing in

comparison to the trial “do not support a finding that there is a substantial likelihood

a fair and impartial trial cannot be preserved with a jury selected from Des Moines

County.” See Iowa R. Crim. P. 2.11(10)(b).3 The court also noted that, because

jury selection had yet to occur, it was without evidence on whether the media

exposure would compromise the impartiality of the potential jury pool.

King was appointed new counsel in February 2016, who made a second

motion to change venue in July. The basis for that motion was a recently published

newspaper article quoting the court’s denial of King’s motion to adjudicate law

points: “‘The defendant does not dispute he rubbed the described area of (her)

body with his fingers,’ [the court] wrote in denying [the] motion. ‘The court

concludes the contact as alleged in count one . . . is contact as used in the

definition of a sex act.’” King argued publication of that ruling was “extremely

prejudicial,” “completely tainted the jury pool,” and made “it absolutely impossible

3 This rule has been renumbered to 2.11(11). 4

for [him] to have a fair trial in Des Moines County.” The court disagreed, finding

King did not establish actual or presumed prejudice:

At this point in time, it is mere guesswork whether or not members of the jury panel have read this particular newspaper article, and if so, what impact the article might have on the ability of the potential jurors to be fair and impartial. This issue can be explored during careful voir dire, which will be reported. During voir dire, if it appears that Defendant cannot receive a fair and impartial trial in Des Moines County, Defendant may renew his motion.

King’s trial started in August. Toward the beginning of jury selection, the

prosecutor asked potential jurors to raise their hands if they had seen or heard

anything about the case in the newspaper or on the radio. Most of the thirty-three

initial potential jurors raised their hands—only eight did not. King claims that

because his attorney did not renew the motion to change venue at that point, he

“was tried by a biased jury.” Relying on State v. Robinson, he argues: “When

pretrial publicity is so pervasive, it cannot be cured by extensive voir dire.” 389

N.W.2d 401, 403 (Iowa 1986). The district court rejected this argument, as do we.

To successfully change venue, King would have needed to prove

either (1) the “publicity attending his case was so pervasive and inflammatory that

prejudice must be presumed, or (2) actual prejudice on the part of the jury.” State

v. Siemer, 454 N.W.2d 857, 860 (Iowa 1990); see also State v. Tompkins, 859

N.W.2d 631, 637 (Iowa 2015) (“[W]here a claimant alleges counsel’s failure to

pursue a particular course breached an essential duty, there is no such duty when

the suggested course would have been meritless.”). Forgoing a claim of actual

prejudice, King likens his case to Robinson, in which the court found: “There was

a barrage of unmistakable warning signals that few people had an open mind on

the questions of defendant’s guilt. Nearly everyone on the jury panel had heard or 5

read about the case and many were acquainted with the prosecution

witnesses.” 389 N.W.2d at 403.

“Whether publicity rises to the level of being presumptively prejudicial

depends on the following factors: the nature, tone, and accuracy of the articles;

their timing in relation to the trial; and the impact of the publicity on the jurors as

revealed through voir dire.” Siemer, 454 N.W.2d at 860. King does not really

address the first two factors, focusing instead on the potential jurors’ exposure to

the media accounts—most of which were published more than a year before trial.

See id.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Fryer v. State
325 N.W.2d 400 (Supreme Court of Iowa, 1982)
State v. Myers
382 N.W.2d 91 (Supreme Court of Iowa, 1986)
Karasek v. State
310 N.W.2d 190 (Supreme Court of Iowa, 1981)
State v. Robinson
389 N.W.2d 401 (Supreme Court of Iowa, 1986)
State v. Gavin
360 N.W.2d 817 (Supreme Court of Iowa, 1985)
State v. Risdal
404 N.W.2d 130 (Supreme Court of Iowa, 1987)
State v. Siemer
454 N.W.2d 857 (Supreme Court of Iowa, 1990)
State v. Ware
338 N.W.2d 707 (Supreme Court of Iowa, 1983)
State of Iowa v. Demetrice De'angelo Tompkins
859 N.W.2d 631 (Supreme Court of Iowa, 2015)
State of Iowa v. Tyler James Webster
865 N.W.2d 223 (Supreme Court of Iowa, 2015)
State of Iowa v. Christopher Clay McNeal
897 N.W.2d 697 (Supreme Court of Iowa, 2017)
Simpson v. State
901 N.W.2d 837 (Court of Appeals of Iowa, 2017)
State v. Jonas
904 N.W.2d 566 (Supreme Court of Iowa, 2017)

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