Jeremy Wayne Ott, Applicant-Appellant v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedOctober 29, 2014
Docket13-1549
StatusPublished

This text of Jeremy Wayne Ott, Applicant-Appellant v. State of Iowa (Jeremy Wayne Ott, Applicant-Appellant 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.

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Jeremy Wayne Ott, Applicant-Appellant v. State of Iowa, (iowactapp 2014).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 13-1549 Filed October 29, 2014

JEREMY WAYNE OTT, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Wapello County, Daniel P. Wilson,

Judge.

Jeremy Ott appeals the district court’s decision denying his application for

postconviction relief. AFFIRMED.

Julie DeVries of DeVries Law Office, P.L.C., Centerville, for appellant.

Thomas J. Miller, Attorney General, Sheryl A. Soich, Assistant Attorney

General, Allen Cook, County Attorney, and Andrew J. Ritland, Assistant County

Attorney, for appellee.

Considered by Danilson, C.J., and Vogel and Bower, JJ. 2

BOWER, J.

Jeremy Ott appeals the district court’s ruling denying his application for

postconviction relief (PCR), claiming the court erred in ruling his defense counsel

did not render ineffective assistance. We affirm.

I. Background Facts and Proceedings

Ott lived in Ottumwa. In July 2009 an Ottumwa convenience store was

robbed. In August 2009 Ott was charged with robbery in the first degree. Ott

was represented by an experienced defense attorney, John Silko, and Ott

demanded a speedy trial. Initially, Silko thought the State’s case against Ott was

weak based on: (1) seven alibi witnesses willing to testify Ott had been at a party

in Newton on the day of the Ottumwa robbery; (2) the lack of eyewitness

testimony identifying Ott as the robber; and (3) the lack of forensic evidence tying

Ott to the scene. Silko’s evaluation changed during trial when the State informed

him of evidence weakening the credibility of Ott’s alibi witnesses.

The State’s case was initially based on: (1) a poor-quality surveillance

video insufficient to positively identify the robber but after Ott’s former girlfriend

viewed it, she believed the robber looked like Ott; (2) Ott owning and pawning a

gun with characteristics similar to the gun used in the robbery; (3) shortly after

the robbery, the police found a discarded shirt two blocks away matching the

description of the robber’s shirt; (4) after testing, the DNA on the discarded shirt

matched Ott’s DNA, and (5) Ott changing his stories about the shirt.1

1 First, Ott denied the shirt was his and told the investigators he had a similar shirt but it was in storage. Eventually, Ott admitted the discarded shirt was his. 3

During Ott’s trial, the prosecutor learned Ott had signed an affidavit of

personal service in Ottumwa on the day of the robbery. The prosecutor

disclosed the new information to Silko and offered to let Ott plead guilty to

second-degree robbery. Silko discussed the plea offer and new information with

Ott. Ott rejected the plea offer, and the jury trial continued. In November 2009

the jury found Ott guilty as charged.

Ott appealed his conviction, alleging his counsel was ineffective for failing

to object to an exhibit label used by the State. In January 2011 we affirmed the

conviction, ruling “even if counsel should have objected to the exhibit, Ott was

not prejudiced by its publication to the jury.” State v. Ott, No. 10-0167, 2011 WL

238435, at *1 (Iowa Ct. App. Jan. 20, 2011).

In August 2011 Ott filed an application for postconviction relief (PCR). In

August 2013 Ott amended his application to include a claim his attorney provided

ineffective assistance of counsel by failing to solicit a plea offer from the State.2

At the hearing on Ott’s application, Silko, prosecutor Allen Cook, and Ott testified.

The PCR court denied Ott’s claim, stating: “The court questions where, as here,

a client demands speedy trial, adamantly maintains his actual innocence, and

expresses repeated unwillingness to accept any resolution other than dismissal

of the charges, a defense attorney would be charged with a duty to solicit a plea

agreement from the State.” The court also denied Ott’s claim that counsel

improperly advised him to reject a plea offer the State made during trial.

2 Ott alleged a second ground concerning a statement made by a State’s witness but no evidence on that ground was presented at the postconviction trial. 4

II. Standard of Review

We review PCR proceedings for errors at law except for when the basis of

relief is constitutional, in which case our review is de novo. Harrington v. State,

659 N.W.2d 509, 519 (Iowa 2003). An applicant’s claim his trial counsel

rendered ineffective assistance is reviewed de novo. Ennega v. State, 812

N.W.2d 696, 701 (Iowa 2012).

To establish an ineffective-assistance-of-counsel claim, Ott must

demonstrate, by a preponderance of the evidence, trial counsel failed to perform

an essential duty and the failure prejudiced him. See Strickland v. Washington,

466 U.S. 668, 687 (1984). We employ a strong presumption counsel performed

reasonably and competently. State v. Cook, 565 N.W.2d 611, 613-614 (Iowa

1997).

III. Ineffective Assistance—Failure to Solicit a Plea Offer and to

Communicate an Existing Plea Offer

On appeal, Ott raises a failure-to-communicate claim. He contends

Cook’s testimony at the PCR hearing shows the State made a plea offer prior to

trial and counsel failed to communicate the State’s plea offer to him. Ott

contends he was unaware of this plea offer until Cook testified at the PCR

hearing. Ott faults the PCR court’s failure to make a specific credibility finding

“regarding the prosecutor” when the testimony of Silko and Cook “conflicted.”

See Tim O’Neill Chevrolet, Inc. v. Forristall, 551 N.W.2d 611, 614 (Iowa 1996)

(“The district court has a better opportunity than we do to evaluate the credibility

of witnesses. So we think factual disputes depending heavily on such credibility 5

are best resolved by the district court.”). Ott also claims the PCR court abused

its discretion in finding no pretrial plea offer was made.

The State contends error is not preserved because Ott’s PCR application

only alleges defense counsel failed to solicit a plea offer from the State. We

assume error is preserved and address Ott’s challenges.

A. The District Court’s Failure to Make a Specific Credibility Finding

Regarding the Prosecutor. Contrary to Ott’s assertion, prosecutor Cook

testified “strictly off my memory” and did not testify an oral pretrial plea offer was

actually made but rather testified in generalities. Cook testified if the State had

made a plea offer, Cook “believe[d] that I would have made an offer of robbery in

the second [degree]. Again, I don’t necessarily have a specific recollection of

that.” Cook reiterated he did not “have any specific recollection about the

negotiations prior to trial except that Mr. Silko was demanding a dismissal.”

Finally, Cook once again testified:

A. . . . As I said, I don’t have a specific recollection of making an offer from the State. I believe that if I would have, it would have been robbery in the second [degree].

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Tim O'Neill Chevrolet, Inc. v. Forristall
551 N.W.2d 611 (Supreme Court of Iowa, 1996)
State v. Cook
565 N.W.2d 611 (Supreme Court of Iowa, 1997)
Harrington v. State
659 N.W.2d 509 (Supreme Court of Iowa, 2003)
Roger B. Ennenga v. State of Iowa
812 N.W.2d 696 (Supreme Court of Iowa, 2012)

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