Ricky Lee Putman v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedJuly 24, 2019
Docket18-0571
StatusPublished

This text of Ricky Lee Putman v. State of Iowa (Ricky Lee Putman 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
Ricky Lee Putman v. State of Iowa, (iowactapp 2019).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 18-0571 Filed July 24, 2019

RICKY LEE PUTMAN, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Fayette County, Richard D. Stochl,

Judge.

Ricky Putman appeals the denial of his application for postconviction relief.

AFFIRMED.

Stuart G. Hoover of Blair & Fitzsimmons, P.C., Dubuque, for appellant.

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

General, for appellee State.

Considered by Vaitheswaran, P.J., and Tabor and Greer, JJ. 2

GREER, Judge.

A postconviction-relief applicant argues his trial counsel was ineffective for

failing to adequately advise him of his right to testify in his own defense and for

failing to keep him informed of the defense strategy, thereby depriving him of the

ability to participate in his defense. The district court determined that the

applicant’s trial counsel did not fail to perform an essential duty and denied the

applicant’s ineffectiveness claims. On our review, we affirm.

I. Background Facts and Proceedings.

The Iowa Supreme Court set forth the relevant facts of the underlying

criminal case in State v. Putman, 848 N.W.2d 1, 3–7 (Iowa 2014). Briefly, Putman

was accused of sexually abusing two-year-old L.R. As the supreme court noted,

pediatric physicians “concluded that L.R. had suffered vaginal penetration injuries,”

which required surgery under general anesthesia and “numerous stitches to repair

the damage.” Putman, 848 N.W.2d at 4. A jury convicted Putman of sexual abuse

in the first degree. He was sentenced to life in prison. On direct appeal of his

conviction, Putman challenged the sufficiency of the evidence and argued that the

trial court improperly admitted evidence of child pornography on his computer. The

Iowa Supreme Court affirmed his conviction. See id. at 8–16.

In September 2014, Putman filed an application for postconviction relief. He

originally raised the same claims as he had on direct appeal. However, after

amending his application, Putman now raises two ineffective-assistance-of-

counsel claims. After a hearing on his amended postconviction application, the

district court denied Putman’s application in its entirety. Putman appeals. 3

II. Standard of Review.

“We generally review the denial of an application for postconviction relief for

correction of errors at law.” Sauser v. State, 928 N.W.2d 816, 818 (Iowa 2019).

However, “[w]e review ineffective-assistance-of-counsel claims de novo.” State v.

Brown, ___ N.W.2d ___, ___, 2019 WL 2710809, at *2 (Iowa 2019).

III. Analysis.

Putman raises his postconviction claims under the Sixth Amendment of the

United States Constitution. The Sixth Amendment provides, “In all criminal

prosecutions, the accused shall enjoy the right . . . to have the Assistance of

Counsel for [their] defence.” U.S. Const. amend. VI. “In order to prevail on an

ineffective-assistance-of-counsel claim, a defendant must demonstrate both that

‘(1) . . . trial counsel failed to perform an essential duty, and (2) this failure resulted

in prejudice.’” Sauser, 928 N.W.2d at 818 (quoting State v. Straw, 709 N.W.2d

128, 133 (Iowa 2006)); see also Strickland v. Washington, 466 U.S. 668, 687–88

(1984). To establish prejudice, Putman must “show the results of the proceeding

would have been different but for counsel’s error.” Sauser, 928 N.W.2d at 819.

Putman argues his trial counsel was ineffective for failing to adequately

advise him of his right to testify in his own defense and for failing to adequately

advise him of the defense theory, thereby preventing him from participating in his

own defense. We will address each claim in turn.

A. Advising Putman Regarding Whether to Testify in His Own

Defense. A criminal defendant has a constitutional right to testify in his own

defense. See Rock v. Arkansas, 483 U.S. 44, 51 (1987). The defendant may

knowingly, intelligently, and voluntarily waive this right. Ledzema v. State, 626 4

N.W.2d 134, 146 (Iowa 2001). The defendant’s counsel must provide advice to

enable the defendant to make an informed choice about testifying at trial, but the

final decision regarding whether to testify is the defendant’s alone. Id. The Iowa

Supreme Court has described counsel’s duty as follows:

Counsel has a duty to advise the defendant about the consequences of testifying so that an informed decision can be made. The decision is often extremely difficult to make, but “can be the single most important factor in a criminal case.” Generally, the advice provided by counsel is a matter of trial strategy and will not support a claim of ineffective assistance absent exceptional circumstances. However, when a defendant follows the misinformed advice of counsel concerning the consequences of testifying, ineffective assistance of counsel may occur.

Id. at 146–47 (citations omitted).

Putman elected not to testify during his criminal trial. Outside the presence

of the jury, his defense counsel asked the court to make a record regarding

Putman’s decision not to testify:

MR. HAWBAKER: I have discussed whether or not Mr. Putman will testify with Mr. Putman. It is his choice not to testify. THE COURT: Anything more need to be said? MR. HAWBAKER: I would just ask that the court inquire of that of Mr. Putman. THE COURT: Mr. Putman, do you mind answering that question? MR. PUTMAN: Yeah, I don’t want to testify THE COURT: Okay. Noted. The jury will not receive any other comment on that other than the uniform instruction on the Defendant’s election not to testify previously given to counsel.

Putman now argues his counsel was ineffective for failing to properly advise

him regarding whether to testify in his own defense. Putman alleges that his trial

counsel told him that testifying was a bad idea and would make him look guilty.

Putman claims that had he been able to testify in his own defense, he could have 5

explained his side of the story and could have confirmed that the child pornography

on his computer was not his.

At the postconviction hearing, Putman’s trial counsel could not specifically

recall the conversation he had with Putman about testifying. However, he did

specifically remember being unsure of exactly what Putman would say in

testimony. His trial counsel was concerned that potential testimony from Putman—

where he denied ownership of the extensive child pornography found on his

computer—would highlight “something that was extremely detrimental to us. And

putting him on the stand and risking opening that door which to me [was] not a

good idea.” His trial counsel further testified that his normal course of conduct is

to tell his clients that whether to testify is “a game-time decision” based on how the

trial has progressed. He tells his clients that it is their right to testify but he would

also have a conversation about the risks and benefits. If at the end of this

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Rock v. Arkansas
483 U.S. 44 (Supreme Court, 1987)
State v. Newman
326 N.W.2d 788 (Supreme Court of Iowa, 1982)
State v. Straw
709 N.W.2d 128 (Supreme Court of Iowa, 2006)
Pettes v. State
418 N.W.2d 53 (Supreme Court of Iowa, 1988)
State of Iowa v. Ricky Lee Putman
848 N.W.2d 1 (Supreme Court of Iowa, 2014)
Wendt v. Manegold Stone Co.
4 N.W.2d 134 (Wisconsin Supreme Court, 1942)
Revette Ann Sauser v. State of Iowa
928 N.W.2d 816 (Supreme Court of Iowa, 2019)

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