HANEGAN v. Miller
2011 U.S. App. LEXIS 24212
8th Cir.2011Background
- Hanegan was convicted in Iowa state court of kidnapping in the first degree, attempted murder, and willful injury, receiving life on the kidnapping charge.
- Fleenor testified to being held in a car, beaten, and partially burned with injuries that required hospitalization; she was later found beneath a car at a cemetery.
- Iowa jury was instructed that kidnapping required proving removal without consent with serious injury, defined as a disabling injury or one causing substantial risk of death or permanent disfigurement.
- Defense theory argued Fleenor volunteered to go to the cemetery; the defense did not challenge the serious-injury element, aiming to limit photos and argue lack of consent.
- Postconviction relief claimed trial counsel was ineffective for not challenging the serious-injury evidence or introducing methamphetamine-induced psychosis evidence; state courts denied relief, and federal habeas followed under AEDPA standards.
- The district court denied the habeas petition; the Eighth Circuit affirmed, applying AEDPA deference and Strickland standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance prejudice under Strickland? | Hanegan contends counsel failed to object to or impeach injury testimony, causing prejudice. | Miller argues no prejudice since injuries were undisputedly serious and evidence supported guilt. | No unreasonable prejudice; prejudice not shown by substantial likelihood of different result. |
| Was there substantial evidence of 'serious injury' under Iowa law? | Hanegan asserts the injuries were overstated or not proven as serious; postconviction shows possible alternative injuries or psychosis. | Fleenor's injuries, including rib fractures and burns, constitute serious injury under Iowa law. | Yes; substantial evidence supported serious injury for purposes of both charges. |
| Did counsel's failure to challenge psychosis/injury testimony prejudice? | Counsel should have introduced evidence of methamphetamine-induced psychosis affecting Fleenor and challenged injury severity. | Counsel's strategy did not render performance deficient given the record of serious injuries. | Not prejudicial under Strickland; district court's denial affirmed. |
| AEDPA application—unreasonable factual or legal determinations by state court? | Iowa court erred in applying Strickland and disregarding contested testimony. | State court reasonably concluded no prejudice and properly applied federal law. | No unreasonable application; state court decision stands. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice standard for ineffective assistance)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (AEDPA deference: unreasonable application differs from incorrect application)
- Williams v. Taylor, 529 U.S. 362 (2000) (define unreasonable application under § 2254(d))
- Yarborough v. Alvarado, 541 U.S. 652 (2004) (reasonable jurists could disagree standard for habeas review)
- Wong v. Belmontes, 558 U.S. 15 (2010) (prejudice inquiry in Strickland emphasizes substantial likelihood, not conceivable possibility)