Keisha L. Magee v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedJanuary 9, 2019
Docket18-0578
StatusPublished

This text of Keisha L. Magee v. State of Iowa (Keisha L. Magee 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
Keisha L. Magee v. State of Iowa, (iowactapp 2019).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 18-0578 Filed January 9, 2019

KEISHA L. MAGEE, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, David P.

Odekirk, Judge.

Keisha Magee appeals the denial of her application for postconviction relief.

AFFIRMED.

Mark C. Smith, State Appellate Defender, and Ashley Stewart, Assistant

Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Zachary Miller, Assistant Attorney

General, for appellee State.

Considered by Tabor, P.J., and Mullins and Bower, JJ. 2

BOWER, Judge.

Keisha Magee appeals the denial of her application for postconviction relief

(PCR) claiming PCR counsel committed two structural errors in her case. She

alternatively claims she was provided ineffective assistance of counsel. We find

Magee has not established structural error occurred during the postconviction trial

and her ineffective-assistance claims brought on appeal for the first time should be

asserted in a separate application.

I. Background Facts & Proceedings

In the early morning hours of September 29, 2013, Magee went to a friend’s

home believing her paramour, John Bass, was on the premises. Magee had a

history of assaulting Bass, and a no-contact order was in place protecting Bass

from Magee. The friend indicated Bass was not at the house and then allowed

Magee in to use the restroom. Magee had been drinking and using illegal

substances that evening. Magee found Bass in an upstairs room. They went

downstairs and argued. Magee punched Bass. Magee then went to the kitchen,

got a knife, and stabbed Bass in the chest in front of two witnesses. Bass died

from the wound.

Magee turned herself in at the police station later that day. She was highly

emotional and was sent to the hospital for the night when she exhibited breathing

difficulties.

In November, the State charged Magee with first-degree murder. Magee

entered into a plea agreement with the State and pleaded guilty to second-degree

murder on April 4, 2014. Magee waived her presentence investigation report and

requested immediate sentencing. She was sentenced to the statutory 3

indeterminate sentence of not more than fifty years imprisonment with a mandatory

minimum of thirty-five years. She did not appeal.

On June 25, 2014, Magee filed an application for PCR counsel but no

application for PCR. She was appointed counsel on July 3, and different counsel

was appointed on November 17, for reasons unrelated to Magee’s case. A Iowa

Rule of Civil Procedure 1.944 notice of dismissal was generated on July 21, 2015.

An application for PCR was filed December 18, 2015, along with a renewed

request for counsel. The application alleged Magee “was not in [the] right state of

mind to make [a] decision on any plea agreement.” Magee’s requested relief was

to renegotiate her plea deal or for a new trial to present new evidence.

On January 7, 2016, the court dismissed the action by operation of rule

1.944, but PCR counsel filed a motion to reinstate the petition, which was granted

on February 5, 2016. Trial was scheduled and rescheduled several times, finally

taking place on January 16, 2018. Magee appeared by phone and testified.

Magee’s trial counsel also testified. The district court denied Magee’s application

for PCR on March 29. She appeals.

II. Standard of Review

We generally review postconviction proceedings for correction of errors at

law. Iowa R. App. P. 6.907; Moon v. State, 911 N.W.2d 137, 142 (Iowa 2018).

However, a PCR application alleging ineffective assistance of counsel raises a

constitutional claim, and our review is de novo. Moon, 911 N.W.2d at 142. 4

III. Analysis

Magee does not allege any legal error by the court or appeal any of the

issues raised and decided in the PCR action.1 Her claims on appeal relate to the

performance of PCR counsel, who Magee claims provided ineffective assistance.

In particular, Magee claims counsel failed to investigate and present evidence and

expert testimony regarding her mental health. Magee categorizes the errors as

structural and if not structural errors then as general ineffective-assistance-of-

counsel claims.

A. Structural error. A structural error arises when counsel’s error

affects the trial’s framework. Krogmann v. State, 914 N.W.2d 293, 313 (Iowa

2018). Iowa courts recognize three types of structural error: “(1) counsel is

completely denied, actually or constructively, at a crucial stage of the proceeding;

(2) where counsel does not place the prosecution’s case against meaningful

adversarial testing; or (3) where surrounding circumstances justify a presumption

of ineffectiveness, such as where counsel has an actual conflict of interest.” Lado

v. State, 804 N.W.2d 248, 252 (Iowa 2011); see also Weaver v. Massachusetts,

137 S. Ct. 1899, 1908 (2017) (categorizing error as structural when the right at

issue protects an interest other than from erroneous conviction, when the effects

of the error are too hard to measure, and when the error always results in

fundamental unfairness). Structural error may render the underlying proceeding

1 Magee’s PCR application requested to withdraw her plea, claiming she was not in the right state of mind to decide on a plea agreement, supported by her change in medication and a mental-health appointment. At her plea hearing, Magee told the court she was on prescription medication meant to help her understand what was going on and what she was doing. 5

“so unreliable the constitutional or statutory right to counsel entitles the defendant

to a new proceeding without the need to show the error actually caused prejudice.”

Lado, 804 N.W.2d at 252. We look at the type of structural error presented in the

case and its effect on the fairness of the criminal proceedings to determine if

prejudice must be shown. Krogmann, 914 N.W.2d at 324 (finding an unlawful total

freeze of assets impairing the defendant’s ability control his defense was

presumptively prejudicial). But see Weaver, 137 S. Ct. at 1908 (noting not all

structural errors “lead to fundamental unfairness in every case”).

The first structural error Magee alleges is her PCR counsel failed to

investigate and present evidence on her mental illness. She argues this failure

constitutes a failure to prepare or present evidence of her claims in a meaningful

adversarial context. Magee claims counsel, despite requesting medical records

and meeting with past treating physicians, did not complete even a minimal

investigation.

Magee testified at length during the PCR hearing. She testified as to her

history of mental-health problems, the effects of her medications and other

controlled substances, and differences in her general actions and reactions when

medicated and not on her medications. During the PCR hearing, she asked if PCR

counsel had mailed consent forms, which PCR counsel confirmed.

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

Related

State v. Ondayog
722 N.W.2d 778 (Supreme Court of Iowa, 2006)
Weaver v. Massachusetts
582 U.S. 286 (Supreme Court, 2017)
Daniel Lado v. State of Iowa
804 N.W.2d 248 (Supreme Court of Iowa, 2011)
Martin Shane Moon v. State of Iowa
911 N.W.2d 137 (Supreme Court of Iowa, 2018)
Robert Krogmann v. State of Iowa
914 N.W.2d 293 (Supreme Court of Iowa, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Keisha L. Magee v. State of Iowa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keisha-l-magee-v-state-of-iowa-iowactapp-2019.