Clayton Robert Adams v. State
387 P.3d 153
Idaho Ct. App. U2016Background
- Adams was convicted by a jury of second‑degree murder and aggravated battery after an altercation in which he stabbed two men; one died. He claimed self‑defense at trial.
- On direct appeal his convictions and sentences were affirmed; he later filed a pro se post‑conviction petition alleging multiple instances of ineffective assistance of counsel and sought funding for an investigator to locate two witnesses.
- The district court granted limited relief on unrelated post‑conviction claims (a resentencing) but summarily dismissed the ineffective‑assistance claims and denied the investigative‑services motion and a motion for reconsideration; Adams appealed.
- Key disputed claims on post‑conviction review: denial of funds/investigator to locate witnesses; counsel’s failure to object to paramedic opinion testimony; counsel’s failure to pursue pretrial or independent DNA testing of victim’s clothing; counsel’s failure to call two witnesses and alleged concession in closing argument.
- The district court allowed post‑conviction DNA testing; the additional testing detected only the deceased victim’s DNA on swabs and did not show transfer from the surviving victim.
Issues
| Issue | Adams' Argument | State's Argument | Held |
|---|---|---|---|
| Motion for investigative services to locate two witnesses | Denial was abuse of discretion; investigator needed to find witnesses who would support self‑defense | Motion was untimely, conclusory, lacked good cause or details about prior efforts; would cause unjustified delay | Denial affirmed: district court acted within discretion given delay, lack of foundation, and risk of fishing expedition |
| Failure to object to paramedic’s opinion that surviving victim had a stab wound | Counsel ineffective for not objecting to opinion testimony by non‑expert; prejudiced defense | Paramedic had sufficient training/experience to qualify under I.R.E. 702; failure to object was a tactical choice | Dismissed: testimony was admissible under I.R.E. 702; counsel’s failure to object deemed strategic, not deficient |
| Failure to seek independent DNA testing pretrial (and post‑conviction testing results) | Counsel should have tested deceased victim’s clothing to show transfer (or absence) of surviving victim’s DNA, supporting self‑defense and impeachment | Post‑conviction testing (granted later) showed only deceased’s DNA; results limited and do not prove exculpatory theory; even if favorable, other trial evidence still supports conviction | Dismissed: limited DNA results do not create reasonable probability of different outcome; counsel not shown deficient or prejudicial |
| Failure to call two witnesses / alleged concession in closing argument | Witnesses would have corroborated that others were aggressors; counsel conceded manslaughter in closing without consent | Plaintiff offered only hearsay/speculation about witnesses; closing argument statements were tactical, preserved self‑defense theory and sought to mitigate charge | Dismissed: no admissible evidence of witnesses’ testimony or availability; closing was strategic and did not abandon self‑defense or concede guilt improperly |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes deficient performance and prejudice test for ineffective assistance of counsel)
- Cronic v. United States, 466 U.S. 648 (recognizes rare circumstances where prejudice may be presumed for breakdown in adversarial process)
- Murphy v. State, 143 Idaho 139 (discovery/funding requests in post‑conviction proceedings governed by trial court discretion; no fishing expeditions)
- Raudebaugh v. State, 135 Idaho 602 (post‑conviction discovery requires court authorization and is limited to protecting substantial rights)
- Cook v. State, 157 Idaho 775 (failure to object is evaluated by whether testimony was arguably admissible and whether decision was tactical)
- Roman v. State, 125 Idaho 644 (standards for summary dismissal of post‑conviction petitions)