Supreme Court of Iowa
Timothy Duane Smith v. State of Iowa
June 7, 2024
Summary
The court vacated the court of appeals decision and affirmed the denial of postconviction relief on three ineffective-assistance claims. It held that Smith failed to show constitutional prejudice from counsel's failure to seek additional peremptory strikes, failed to prove a breach of duty concerning alleged juror misconduct, and failed to overcome the presumption that counsel's decision not to call certain witnesses was reasonable trial strategy. The court also rejected cumulative-prejudice analysis because it found no breaches of duty on the claims it evaluated.