Trent Allen Williams v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedJune 21, 2023
Docket21-1985
StatusPublished

This text of Trent Allen Williams v. State of Iowa (Trent Allen Williams 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
Trent Allen Williams v. State of Iowa, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1985 Filed June 21, 2023

TRENT ALLEN WILLIAMS, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Jeffrey Farrell, Judge.

The applicant appeals the district court’s denial of his request for

postconviction relief from his convictions for failure to register as a sex offender

and assault on a peace officer. AFFIRMED.

Agnes Warutere, Ankeny, for appellant.

Brenna Bird, Attorney General, and Linda J. Hines, Assistant Attorney

General, for appellee State.

Considered by Bower, C.J., Badding, J., and Carr, S.J.*

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

(2023). 2

CARR, Senior Judge.

Trent Williams appeals the district court’s denial of his request for

postconviction relief (PCR) from his convictions for failure to register as a sex

offender and assault on a peace officer. He claims he received ineffective

assistance because defense counsel allowed him to plead guilty when there were

questions about his competency. He also claims he received ineffective

assistance from PCR counsel. We affirm the district court’s decision finding

Williams has not shown he received ineffective assistance at the time of his guilty

pleas. In addition, he has not shown he received ineffective assistance from PCR

counsel.

I. Background Facts & Proceedings

In AGCR307746, Williams was charged with failure to register as a sex

offender, in violation of Iowa Code section 692A.104 (2017). On August 4, 2017,

the court ordered a competency evaluation for Williams and suspended the

proceedings. On September 8, the court found, “based on the interactions of the

Defendant with the Court[,] that he is competent to stand trial and the stay

previously imposed should be lifted and this criminal proceeding is reinstated.”

Williams appeared for a hearing on September 21, and based on his

conduct the court found his competency was questionable. The court ordered

Williams to be transported to a psychiatric hospital for an evaluation. Pursuant to

section 812.3 further proceedings were suspended.1 The State filed a

1 Section 812.3 provides: 1. If at any stage of a criminal proceeding the defendant or the defendant’s attorney, upon application to the court, alleges specific facts showing that the defendant is suffering from a mental 3

psychiatrist’s report on November 17 that gave the opinion Williams was

competent to stand trial. Following a hearing, on November 27 the court found

Williams was competent and the stay was lifted.

When Williams was determined to be competent, the State charged him in

SRCR311553 with assault on a peace officer, in violation of section 708.3A(4). In

December, Williams entered into a combined plea agreement for violation of the

sex offender registry and assault on a peace officer. The district court accepted

his guilty pleas. His sentences were suspended, and he was placed on probation

for a period of two years.

On March 23, 2018, the State filed a report of probation violations in

AGCR307746 and SRCR311553, alleging Williams “punched an individual in the

face while at a hospital” and was not living at his reported residence. While the

matter was pending, the court ordered that Williams have a competency

disorder which prevents the defendant from appreciating the charge, understanding the proceedings, or assisting effectively in the defense, the court shall suspend further proceedings and determine if probable cause exists to sustain the allegations. The applicant has the burden of establishing probable cause. The court may on its own motion schedule a hearing to determine probable cause if the defendant or defendant’s attorney has failed or refused to make an application under this section and the court finds that there are specific facts showing that a hearing should be held on that question. . . . 2. Upon a finding of probable cause sustaining the allegations, the court shall suspend further criminal proceedings and order the defendant to undergo a psychiatric evaluation to determine whether the defendant is suffering a mental disorder which prevents the defendant from appreciating the charge, understanding the proceedings, or assisting effectively in the defense. . . . If an evaluation has been conducted within thirty days of the probable cause finding, the court is not required to order a new evaluation and may use the recent evaluation during a hearing under this chapter. 4

evaluation. Williams was transported to the Iowa Medical and Classification

Center where he was evaluated by another psychiatrist in August 2018. Williams

was diagnosed with schizoaffective disorder. The psychiatrist determined he was

competent to stand trial, opining:

Even when his manner of speaking is disorganized, he is eventually able to provide logical responses. He understands the charges against him. He has a rational and factual understanding of the court process, including key personnel and their functions. He is able to work effectively with defense counsel, although some challenges may arise. While he was irritable and argumentative at times during this interview, he remained calm and cooperative at other times when discussing the same topics. . . . He is aware of appropriate courtroom behavior, and he appears able to manage his own behavior.

Following a chapter 812 hearing, on September 12 the court entered an order

finding Williams competent to stand trial.

Williams represented himself for the probation violation hearing. The court

found, “Based on the evidence presented, Defendant’s mental health issues and

the fact that this incident occurred while Defendant was seeking both medical

attention and mental [health] attention the Court Orders that the Defendant should

remain on probation under all of the initial terms of probation.”

On December 20, the State filed a new report of probation violations in

AGCR307746 and SRCR311553, alleging Williams was not participating in

mental-health treatment and was not living at his reported residence. Also, on

January 11, 2019, the State alleged Williams violated probation by failing to comply

with the sex offender registry requirements. The State further charged Williams in

FECR323465 with failure to comply with the sex offender registry, second or 5

subsequent offense, a class “D” felony. The trial information was amended to

charge Williams as a habitual offender.

At this point, the proceedings in AGCR307746 and SRCR311553 took

different paths. In AGCR307746, the court entered an order on April 1 suspending

the proceedings under section 812.3. The court scheduled a hearing “to determine

whether there is probable cause that defendant is suffering from a mental disorder

which prevents him/her from appreciating the charge, understanding the

proceedings, or assisting effectively in the defense, and whether the Court should

order a psychiatric evaluation.” No further orders were entered regarding

Williams’s competency in AGCR307746.

In SRCR311553, on April 1, the court found “probable cause that the

defendant is suffering from a mental disorder which prevents the defendant from

appreciating the charge, understanding the proceedings, or assisting effectively in

the defense.” The proceedings were suspended, and Williams was referred for a

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Related

State v. Maxwell
743 N.W.2d 185 (Supreme Court of Iowa, 2008)
State v. Hutchison
341 N.W.2d 33 (Supreme Court of Iowa, 1983)
State v. Rhode
503 N.W.2d 27 (Court of Appeals of Iowa, 1993)
State v. Rieflin
589 N.W.2d 749 (Court of Appeals of Iowa, 1998)
Dunbar v. State
515 N.W.2d 12 (Supreme Court of Iowa, 1994)
Deandre D. Goode v. State of Iowa
920 N.W.2d 520 (Supreme Court of Iowa, 2018)
Cathryn Ann Linn v. State of Iowa
929 N.W.2d 717 (Supreme Court of Iowa, 2019)

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