William Paul Roland v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedOctober 30, 2024
Docket23-0671
StatusPublished

This text of William Paul Roland v. State of Iowa (William Paul Roland 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
William Paul Roland v. State of Iowa, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0671 Filed October 30, 2024

WILLIAM PAUL ROLAND, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Scott J. Beattie, Judge.

An applicant appeals from the district court’s denial of his application for

postconviction relief related to his criminal conviction in Polk County. AFFIRMED.

Jessica Donels of Parrish Kruidenier L.L.P., Des Moines, for appellant.

Brenna Bird, Attorney General, and Thomas J. Ogden (until withdrawal) and

Louis S. Sloven, Assistant Attorneys General, for appellee State.

Considered by Tabor, C.J., Badding, J., and Carr, S.J.* Buller, J., takes no

part.

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

(2024). 2

CARR, Senior Judge.

William Roland appeals from the district court’s denial of his application for

postconviction relief (PCR) related to his 2018 criminal conviction in Polk County

for one count of sexual exploitation of a minor, in violation of Iowa Code

section 728.12(3) (2017). He argues that his trial counsel was ineffective for failing

to object to the lack of unanimity in the charge and jury verdict and failing to consult

experts for his defense. Because his counsel was not ineffective, we affirm.

I. Background Facts and Proceedings

In October 2017, Roland was attending a deposition at the Polk County

courthouse for a different criminal case in which he was charged with one count of

sexual exploitation of a child, in violation of Iowa Code section 728.12(3). At that

deposition, a prosecutor in the case noticed that Roland was carrying two pictures

alleged to be child pornography in a notebook. The prosecutor explained that “one

of the pictures was of a naked minor black female holding open her vagina. The

other picture is a mixture of naked adults and naked minor children hanging around

what appears to be a campsite.” Following this incident, Roland was charged with

one count of sexual exploitation of a minor, in violation of Iowa Code

section 728.12(3). The matter was tried in September 2018, and Roland was

found guilty of one count of sexual exploitation of a child. On direct appeal his

conviction was affirmed and his sentence was affirmed in part, vacated in part, and

remanded for resentencing for recalculation of Roland’s ability to pay restitution.

See State v. Roland, No. 18-1917, 2020 WL 7021508, at *4 (Iowa Ct. App. Nov.

30, 2020). Roland then applied for PCR, which the district court denied. We now

review. 3

II. Standard of Review

Iowa Code section 822.8 forbids PCR applicants from raising any ground

not raised at trial absent a “sufficient reason.” Because Roland did not raise the

issue of a nonunanimous verdict at trial and does not provide explanation for why

he is raising it for the first time in his PCR application, we only consider that issue

in the context of an ineffective assistance of counsel claim. Claims for ineffective

assistance of counsel are reviewed de novo. Ledezma v. State, 626 N.W.2d 134,

141 (Iowa 2001).

III. Discussion

To prevail on a claim of ineffective assistance of counsel, an applicant “must

typically show that (1) counsel failed to perform an essential duty and (2) prejudice

resulted.” State v. Keller, 760 N.W.2d 451, 452 (Iowa 2009). “[T]here is a strong

presumption trial counsel’s conduct fell within the wide range of reasonable

professional assistance.” State v. Graves, 668 N.W.2d 860, 881 (Iowa 2003)

(citation omitted).

“Miscalculated trial strategies and mere mistakes in judgment normally do

not rise to the level of ineffective assistance of counsel.” Ledezma, 626 N.W.2d at

143. But such tactical decisions must “satisfy the ultimate test: whether ‘under the

entire record and totality of the circumstances’ counsel performed competently.”

Graves, 668 N.W.2d at 881. “When complaining about the adequacy of an

attorney’s representation, it is not enough to simply claim that counsel should have

done a better job.” Dunbar v. State, 515 N.W.2d 12, 15 (Iowa 1994). On appeal,

“[t]he applicant must state the specific ways in which counsel’s performance was 4

inadequate and identify how competent representation probably would have

changed the outcome.” Id.

We address each of Roland’s arguments in turn.

A. Unanimity in Charge and Jury Verdict

Roland first contends his trial counsel was ineffective for failing to object to

the lack of unanimity in the charge and the jury verdict.

The jury shall “agree[] on a verdict unanimously . . . .” Iowa R. Crim. P.

2.22(5). In reaching a verdict the jury need not “concur in a single view of the

transaction disclosed by the evidence. If the conclusion may be justified upon

either of two interpretations of the evidence, the verdict cannot be impeached by

showing that a part of the jury proceeded upon one interpretation and part upon

another.” State v. Duncan, 312 N.W.2d 519, 523 (Iowa 1981) (citation omitted).1

In Duncan, the State alleged that Duncan entered both a marina and a boat

with the intent to commit a theft. Id. The jury instructions did not require that the

jury agree on whether it was Duncan’s breaking, entering, or remaining in the

marina or the boat that satisfied the first element for burglary in the second degree.

Id. at 522–23. Duncan argued the jury should have been required to separately

and unanimously find that his actions in relation to the marina or boat met the first

1 Addressing the State’s reliance on Duncan in its brief, Roland in reply advances

that Duncan is “distinguishable, unworkable and ought to be overturned,” and later that “it should be disregarded.” Duncan was alleged to have burglarized a marina and a boat within it at the same time and place. Roland was alleged to have possessed two images containing child pornography at the same time and place. We have struggled to distinguish the two scenarios. Roland argues with some force that he might have been convicted with some but not all jurors agreeing on which photo was contraband. But that was the case for Duncan as well. We are not at liberty to overrule or disregard precedent of our supreme court. 5

element for burglary. Id. at 522. But our supreme court held that this is not

required. Id. at 523 (“[W]here a statute makes either of two or more distinct acts

connected with the same general offense and subject to the same measure and

kind of punishment indictable separately and as distinct crimes when each shall

have been committed by different persons and at different times, they may, when

committed by the same person and at the same time, be coupled in one count as

together constituting but one offense . . . .” (alteration in original) (citation

omitted)).

In State v. Bratthauer, 354 N.W.2d 774, 776 (Iowa 1984), the supreme court

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

Related

State v. Westeen
591 N.W.2d 203 (Supreme Court of Iowa, 1999)
State v. Bratthauer
354 N.W.2d 774 (Supreme Court of Iowa, 1984)
Ledezma v. State
626 N.W.2d 134 (Supreme Court of Iowa, 2001)
State v. Graves
668 N.W.2d 860 (Supreme Court of Iowa, 2003)
State v. Keller
760 N.W.2d 451 (Supreme Court of Iowa, 2009)
State v. Duncan
312 N.W.2d 519 (Supreme Court of Iowa, 1981)
Dunbar v. State
515 N.W.2d 12 (Supreme Court of Iowa, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
William Paul Roland v. State of Iowa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-paul-roland-v-state-of-iowa-iowactapp-2024.