State v. Kraus

397 N.W.2d 671, 1986 Iowa Sup. LEXIS 1351
CourtSupreme Court of Iowa
DecidedDecember 17, 1986
Docket84-1047
StatusPublished
Cited by36 cases

This text of 397 N.W.2d 671 (State v. Kraus) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Kraus, 397 N.W.2d 671, 1986 Iowa Sup. LEXIS 1351 (iowa 1986).

Opinions

HARRIS, Justice.

Contending he was denied effective assistance of counsel the defendant appeals following his conviction of second-degree murder. Iowa Code §§ 707.1, 707.3 (1983). He also appeals from a denial of postcon-viction relief on the same grounds. The case, is unusual in that the defendant received inaccurate legal advice during plea negotiations instead of at trial. Defendant claims he relied on bad advice concerning the elements of second-degree murder and therefore declined an offer to plead to a lesser offense. We conditionally reverse the trial court. So doing we vacate a decision by the court of appeals.

Because the assignments of error address the quality of legal representation the facts relating to the criminal charge can be stated in summary form. Defendant’s sister, Carol, moved into a house with another woman named Marilyn. Defendant later moved into the house and Carol thereafter moved out without paying rent to Marilyn. Marilyn and defendant told Carol they would keep Carol’s furniture until the rent was paid.

Carol obtained the assistance of her (and defendant’s) uncle George Bain to help retrieve her furniture. Bain, his wife, and Carol went to the house. An argument ensued and culminated in defendant shooting and killing Bain. As is typical there were conflicting versions of the altercation. According to defendant he grabbed a rifle in the basement only to scare his uncle who had followed him there and it accidentally discharged. The State’s testimony indicated defendant intended to shoot the victim.

Defendant was arrested for second-degree murder but the State offered to accept a plea of involuntary manslaughter.

Although there is some doubt about the matter we must assume Kraus’ trial attorney mistakenly told him the State would be required to prove a specific intent in order to obtain a second-degree murder conviction. Testimony on the question at the postconviction hearing was conflicting. Defendant’s trial counsel testified in considerable detail that he accurately advised Kraus on the elements of the charge, whereas Kraus testified the attorney told him the State would have to prove a specific intent to kill as an element of second-degree murder.

On this record we cannot accept counsel’s version of the advice. During cross-examination by Kraus’ postconviction counsel the original defense attorney stated he did in fact tell Kraus that, in order to convict him of second-degree murder, the State would have to prove he had a specific intent to kill. On appeal the State justifies this cross-examination testimony as a misstatement. On review it must be said that the testimony casts considerable doubt on the advice and lends credence to Kraus’ testimony.1 We take the misadvice as established.

I. Intent was aptly explained in a court of appeals’ dissenting opinion in this case:

According to Iowa case law, it is well established that “[fjirst degree murder is distinguished from second degree murder in that an element of first degree murder is specific intent to kill, while this element is not required in second degree murder.” State v. Reese, 259 N.W.2d 771, 778 (Iowa 1977); State v. Smith, 242 [673]*673N.W.2d 320, 326 (Iowa 1976); State v. Leedom, 247 Iowa 911, 916, 76 N.W.2d 773, 776 (1966); State v. Miller, 359 N.W.2d 508, 511 (Iowa Ct.App.1984). Second-degree murder does require proof of malice aforethought:
While malice aforethought is the specific state of mind necessary to convict of murder, it is far different from the specific intent which is a necessary element of murder in the first degree. It may be express or implied from the acts and conduct of defendant.
State v. Gramenz, 256 Iowa 134, 142, 126 N.W.2d 285, 290 (1964). Malice aforethought is commonly defined as:
A fixed purpose or design to do some physical harm to another which exists prior to the act committed. It need not exist for any particular length of time and requires only such deliberation as would make a person appreciate and understand the nature of the act and its consequences, as distinguished from an act done in the heat of passion.
State v. Higginbotham, 351 N.W.2d 513, 515 (Iowa 1984) quoting State v. Sharpe, 304 N.W.2d 220, 226 (Iowa 1981).

Our rules for considering claims of ineffective assistance of counsel are well understood. Because a fundamental constitutional right is at issue we make an independent evaluation of the totality of relevant circumstances. This amounts to a de novo review. Taylor v. State, 352 N.W.2d 683, 684 (Iowa 1984). To establish an ineffectiveness claim one must prove: (1) counsel failed to perform an essential duty and (2) prejudice resulted. State v. Hrbek, 336 N.W.2d 431, 436 (Iowa 1983). A claimant must satisfy this burden by a preponderance of all the evidence. Kellogg v. State, 288 N.W.2d 561, 563 (Iowa 1980).

The first prong (failure of essential duty) is not satisfied by a mere showing that trial strategy backfired or that another attorney would have tried the case differently. Fryer v. State, 325 N.W.2d 400, 413-15 (Iowa 1982). We ordinarily refuse to second-guess trial tactics, strategies, or judgment calls. Sallis v. Rhoads, 325 N.W.2d 121, 123 (Iowa 1982).

The second prong (prejudice) requires a showing that the failure worked to the client’s actual and substantial disadvantage. To qualify it must appear that the failure amounted to “a denial of the accused’s due process right to a fair trial, fundamental miscarriage of justice, or an equivalent constitutional deprivation.” State v. Miles, 344 N.W.2d 231, 234 (Iowa 1984). The United States Supreme Court described prejudice this way:

The defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.

Strickland v. Washington, 466 U.S. 668, 697, 104 S.Ct. 2052, 2069, 80 L.Ed.2d 674, 698 (1984).

Misadvice on a matter so basic as the elements of the criminal charge qualifies under the foregoing incompetent representation standard. See State v. Schoelerman, 315 N.W.2d 67

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

Related

People v. Clark
940 N.E.2d 755 (Appellate Court of Illinois, 2010)
State Of Iowa Vs. June Betty Lyman
Supreme Court of Iowa, 2010
State v. Lyman
776 N.W.2d 865 (Supreme Court of Iowa, 2010)
State v. Greuber
2007 UT 50 (Utah Supreme Court, 2007)
Commonwealth v. Mahar
809 N.E.2d 989 (Massachusetts Supreme Judicial Court, 2004)
State v. Taccetta
797 A.2d 884 (New Jersey Superior Court App Division, 2002)
Wanatee v. Ault
101 F. Supp. 2d 1189 (N.D. Iowa, 2000)
State v. Query
594 N.W.2d 438 (Court of Appeals of Iowa, 1999)
Collins v. State
588 N.W.2d 399 (Supreme Court of Iowa, 1998)
Osborne v. Commonwealth
992 S.W.2d 860 (Court of Appeals of Kentucky, 1998)
Osborn v. State
573 N.W.2d 917 (Supreme Court of Iowa, 1998)
People v. Curry
Illinois Supreme Court, 1997
State v. Johnson
485 S.E.2d 315 (Court of Appeals of North Carolina, 1997)
State v. Bugely
562 N.W.2d 173 (Supreme Court of Iowa, 1997)
State v. Klindt
542 N.W.2d 553 (Supreme Court of Iowa, 1996)
State v. Cornelison
538 N.W.2d 864 (Court of Appeals of Iowa, 1995)
State v. Johnson
534 N.W.2d 118 (Court of Appeals of Iowa, 1995)
State v. Howes
525 N.W.2d 874 (Court of Appeals of Iowa, 1994)
Alvernaz v. Ratelle
831 F. Supp. 790 (S.D. California, 1993)
Caldwell v. State
494 N.W.2d 213 (Supreme Court of Iowa, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
397 N.W.2d 671, 1986 Iowa Sup. LEXIS 1351, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kraus-iowa-1986.