Douglas Steinemer v. State
Background
- Steinemer pleaded guilty to first-degree kidnapping and rape pursuant to a plea agreement and later sought to withdraw his plea claiming he had not reviewed a victim interview recording before pleading.
- On direct appeal the denial of his motion to withdraw was affirmed; appellate court noted the same information in recordings was available in police reports and grand jury transcripts.
- Steinemer filed a verified post-conviction petition alleging multiple ineffective-assistance-of-counsel claims, including that trial counsel failed to investigate and instructed him to lie on a guilty-plea questionnaire about having reviewed the evidence.
- Trial counsel allegedly told Steinemer the court would not accept a plea if he answered the questionnaire’s evidence-review question "no," and advised that nothing in the recording would help Steinemer’s defense; Steinemer then changed the answer to "yes."
- The district court granted the State’s motion for summary dismissal, finding no genuine issue of material fact: res judicata applied to the investigation claim, and the record did not support that counsel instructed Steinemer to lie.
- Steinemer appealed, arguing counsel’s conduct in counseling dishonesty violated the Sixth Amendment; the Court of Appeals affirmed summary dismissal.
Issues
| Issue | Plaintiff's Argument (Steinemer) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether counsel was deficient for failing to provide Steinemer the opportunity to review the victim interview before pleading | Counsel failed to investigate and withheld or failed to produce a video that could have supported withdrawal or defense | Res judicata/direct appeal resolved this; same information was available in police reports and grand jury transcripts | Dismissed — res judicata and no genuine issue of material fact |
| Whether counsel instructed or encouraged Steinemer to lie on the guilty-plea questionnaire | Counsel told Steinemer to check "yes" to get plea accepted, which Steinemer characterizes as counsel advising dishonesty | Counsel’s statement was a truthful description of how to obtain the court’s acceptance; Steinemer chose to change his answer relying on counsel’s assessment that the video contained nothing helpful | Dismissed — no deficient performance; no evidence counsel urged falsehood |
| Whether counsel’s alleged misconduct met Strickland prejudice standard for pleas (would have insisted on trial) | Had counsel properly investigated or advised, Steinemer would not have pled guilty and would have insisted on trial | No admissible evidence shows reasonable probability he would have rejected the plea; tactical choices not shown to be uninformed | Dismissed — prejudice not established |
| Whether summary dismissal was improper given affidavit and record | Affidavit asserts factual disputes about counsel’s conduct | Court may disregard conclusory allegations unsupported by admissible evidence; must construe facts for petitioner but may draw probable inferences | Dismissed — no genuine issue of material fact warranted trial |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance standard of deficient performance and prejudice)
- Plant v. State, 143 Idaho 758 (prejudice standard for guilty-plea ineffective-assistance claims requires reasonable probability petitioner would have gone to trial)
- Aragon v. State, 114 Idaho 758 (attorney performance judged by objective reasonableness)
- Wolf v. State, 152 Idaho 64 (petition must present admissible evidence or be dismissed)
- Rhoades v. State, 148 Idaho 247 (post-conviction relief is civil in nature)
- Gonzales v. State, 151 Idaho 168 (strategic decisions not second-guessed absent inadequate preparation or ignorance of law)
- Hayes v. State, 146 Idaho 353 (trial court may draw most probable inferences from uncontroverted evidence)