David Deshawn Bradford, Applicant-Appellant v. State of Iowa, 15-0811

In 2005, David Bradford was convicted of possession of a controlled substance with intent to deliver (second offense and as a habitual offender) after officers stopped a vehicle he was driving; drugs were found in a front passenger’s book bag.
Bradford pursued direct appeal (unsuccessful) and later filed a postconviction relief (PCR) application raising ineffective-assistance-of-counsel claims.
At the PCR evidentiary hearing, Bradford argued trial counsel should have called De’Taris Smith, who had communicated with the passenger and allegedly could identify the passenger as the owner of the drugs.
Smith testified at the PCR hearing that he spoke with the passenger and attempted to contact Bradford’s trial attorney; he also told a police investigator about the calls.
Trial counsel testified he knew of Smith but declined to call him because Smith had previously referred to Bradford as "a drug dealer," and counsel reasonably believed Smith’s testimony could hurt rather than help the defense.
The PCR court credited trial counsel’s testimony, found Smith not credible, and denied relief; the court did not rule on a plea-offer/plea-advice ineffective-assistance claim, which Bradford raised on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to call witness (Smith)	Smith would have identified the passenger as the drugs’ owner and exculpated Bradford	Counsel reasonably declined to call Smith because Smith had called Bradford a "drug dealer" and might harm the defense	No breach of duty; counsel’s decision was strategic and credibility findings support denial
Failure to address plea offer / inaccurate advice on maximum sentence	A plea offer was made and counsel failed to accurately advise Bradford of his maximum sentence, harming plea negotiation	State/PCR court did not adjudicate the claim at the PCR level (no ruling to review)	Issue not decided by PCR court; appellate court will not review because it was not raised and decided below

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance-of-counsel standard: duty and prejudice)
Nguyen v. State, 878 N.W.2d 744 (Iowa 2016) (de novo review of ineffective-assistance claims)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (appellate courts give weight to trial court credibility findings)
Schrier v. State, 347 N.W.2d 657 (Iowa 1984) (strategic decisions not to call witnesses can be reasonable trial tactics)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (appellate courts ordinarily will not decide issues not raised and decided in the district court)

Affirmed: the district court’s denial of Bradford’s postconviction relief application.