Irwin Ryan Ray Adams v. State
158 Idaho 530
Idaho2015Background
- In 2009 Adams crashed at high speed; his passenger died and Adams was convicted of felony vehicular manslaughter after a 2011 trial where the State’s reconstruction expert estimated ~108 mph.
- Defense retained accident reconstructionist Carl Cover, who preliminarily estimated 70–75 mph but never received requested scene photos or inspected the vehicle; Cover was not called at trial.
- Adams filed a post-conviction petition claiming ineffective assistance of counsel for failing to present Cover’s testimony and for failing to investigate mechanical limitations of Adams’s vehicle; he submitted affidavits from Cover and a mechanic.
- The district court issued a notice of intent to dismiss, finding Cover’s affidavit conclusory/speculative and noting the vehicle had been largely destroyed before trial; the court summarily dismissed the petition.
- The Court of Appeals affirmed; the Idaho Supreme Court granted review and affirmed the district court, holding Cover’s proffered testimony inadmissible and that mechanic evidence would not create a reasonable probability of a different verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel’s failure to present Cover’s expert testimony was prejudicial under Strickland | Adams: Cover would have shown ISP calculations were erroneous and that Adams traveled only ~75 mph, undermining gross-negligence finding | State: Cover’s affidavits were speculative, lacked factual foundation, and thus inadmissible; even if admitted, they would not likely change verdict | Held: No prejudice — Cover’s proffer was conclusory/speculative and inadmissible; uncontroverted crash evidence would still support conviction |
| Whether counsel’s failure to investigate/present evidence of vehicle mechanical limitations prejudiced Adams | Adams: mechanic would show vehicle incapable of 108 mph, supporting defense and undermining gross negligence | State: vehicle and motor were unavailable pre-trial; mechanic’s affidavit was equivocal and at best addressed only possible top speed, not gross negligence | Held: No prejudice — mechanic’s testimony would not likely change outcome given overwhelming trial evidence of reckless driving |
| Proper standard for summary dismissal of a post-conviction ineffective-assistance claim | Adams: disputed factual evidence required drawing inferences in his favor and an evidentiary hearing | State: court may exclude conclusory or speculative expert opinions and draw inferences from uncontroverted facts | Held: District court applied correct law; may discount conclusory expert opinions and draw most probable inferences from uncontroverted facts |
| Admissibility of expert opinion challenging ISP reconstruction | Adams: Cover’s opinions challenged ISP methodology and conclusions | State: Expert must identify factual basis and methodology; mere assertion of error is speculative | Held: Cover’s affidavits lacked foundation (no scene measurements, no independent analysis) and were properly deemed speculative and inadmissible |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (established two-prong ineffective assistance standard)
- Payne v. State, 146 Idaho 548 (post-conviction petitions require admissible supporting evidence; summary dismissal standard)
- Bromley v. Garey, 132 Idaho 807 (trial court discretion on admissibility of expert testimony; experts need proper factual foundation)
- Karlson v. Harris, 140 Idaho 561 (expert testimony is speculative when evidence is insufficient for certain knowledge)
- Loomis v. City of Hailey, 119 Idaho 434 (when bench tries case, judge may draw most probable inferences from uncontroverted facts)