Freddie Renier, Applicant-Appellant v. State of Iowa, 16-1876

Freddie Renier was convicted of first-degree robbery and assault while participating in a felony; he admitted brandishing a knife and stabbing the victim but disputed intent to commit theft.
On direct appeal, this court upheld the convictions, finding sufficient evidence Renier intended to commit theft when he dispossessed the victim of a necklace.
Renier filed a postconviction relief (PCR) petition arguing the pocket knife was not a "dangerous weapon" and the injury was not a "serious injury," and alleging ineffective assistance of trial and appellate counsel.
The PCR court did not make findings on Renier's ineffective-assistance claim, and Renier did not move the court to rule on that issue at the PCR level.
The court treated many of Renier's PCR claims as issues that should have been raised on direct appeal and held they are barred under Iowa Code § 822.2 unless Renier shows sufficient reason for not raising them earlier and actual prejudice.
Because Renier failed to preserve the ineffective-assistance claim at the PCR level and did not demonstrate sufficient reason or prejudice for failing to raise the sufficiency issues on direct appeal, the court affirmed the PCR denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that knife was a "dangerous weapon" / injury was "serious"	Renier: evidence did not show the pocket knife was a dangerous weapon per se or that the injury was serious	State: prior direct appeal established sufficient evidence of intent and the weapon/assault elements	Court: Claims should have been raised on direct appeal; barred in PCR absent sufficient reason and prejudice, which Renier did not show; PCR denial affirmed
Ineffective assistance of trial counsel	Renier: counsel failed to raise/argue meritorious issues, object, or correct charges/instructions	State: no preserved ruling or factual development at PCR to support the claim	Court: PCR court made no findings and Renier failed to seek a ruling—issue not preserved for appellate review; affirmed
Ineffective assistance of appellate counsel (pro se brief advice)	Renier: appellate counsel wrongly advised he could not file a pro se brief	State: claim not developed/testified to at PCR hearing	Court: Claim not preserved or developed at PCR; no relief granted
Procedural bar under Iowa Code § 822.2 / res judicata principles	Renier: some claims were not addressed on appeal and thus are not barred	State: PCR is not a substitute for direct review; claims should have been raised on direct appeal	Court: Section 822.2 bars claims not raised on direct appeal unless sufficient reason and prejudice shown; Renier failed to meet burden

Nguyen v. State, 878 N.W.2d 744 (Iowa 2016) (review standard: de novo for constitutional claims)
Everett v. State, 789 N.W.2d 151 (Iowa 2010) (PCR is not a substitute for direct appeal; ineffective-assistance can supply cause)
Berryhill v. State, 603 N.W.2d 243 (Iowa 1999) (claims not raised on direct appeal barred in PCR absent cause and prejudice)
Boyle v. Alum-Line, Inc., 710 N.W.2d 741 (Iowa 2006) (preservation: party must request ruling to preserve error when court fails to decide an issue)
Lamasters v. State, 821 N.W.2d 856 (Iowa 2012) (preservation of error requires pointing out district court's failure to decide an issue)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issues must be raised and decided by district court before appellate review)