Jamaal Joshua Leslie, Applicant-Appellant v. State of Iowa, 16-1397

Jamaal Leslie was convicted of first-degree murder by a jury on June 2, 2012; conviction was affirmed on direct appeal.
Leslie filed an application for postconviction relief (PCR) in July 2014 and later amended it, adding pro se claims that his statements to police were involuntary under constitutional and common-law standards.
At the PCR trial, Leslie alleged both trial counsel and PCR counsel were ineffective for failing to fully develop and press a suppression/involuntariness theory regarding his police statements.
The PCR court denied Leslie’s application after a contested hearing; Leslie appealed the denial on the ground PCR counsel was ineffective for not adequately challenging trial counsel’s performance.
On appeal the court reviewed ineffective-assistance claims de novo and examined whether PCR counsel performed an essential duty and whether any deficiency caused prejudice; the court concluded PCR counsel had questioned trial counsel about suppression and discussed voluntariness with Leslie, so PCR counsel did not fail to perform an essential duty.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PCR counsel was ineffective for failing to fully develop a claim that trial counsel should have moved to suppress Leslie’s statements as involuntary	Leslie: PCR counsel failed to present or highlight record evidence showing involuntariness and thus failed an essential duty	State: PCR counsel questioned trial counsel about suppression and discussed voluntariness at the PCR hearing; record shows adequate development	Court: PCR counsel did not fail an essential duty; ineffective-assistance claim rejected

Everett v. State, 789 N.W.2d 151 (Iowa 2010) (standard of review for PCR denials)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (de novo review for constitutional claims and Strickland framework applied)
Strickland v. Washington, 466 U.S. 668 (1984) (two-pronged ineffective assistance test: performance and prejudice)