James Logan Bartell v. State
Background
- James Bartell convicted by jury of two counts of lewd conduct with children under 16; sentenced to unified 20 years with 8 years determinate.
- Bartell filed a pro se post-conviction petition alleging ineffective assistance of multiple attorneys (pretrial counsel Cindy Campbell, trial counsel James Archibald, appellate counsel Spencer Hahn) among others.
- Key allegations: Campbell failed to investigate/seek competency evaluation for Bartell’s asserted mental-health disabilities; Archibald failed to present evidence that the victims had been abused by maternal relatives; Hahn failed to appeal denial of a new-trial motion.
- The State moved for summary dismissal; the district court summarily dismissed claims against Campbell, Archibald, and Hahn (granted for some other counsel and granted relief as to one counsel not at issue here).
- On appeal Bartell argued the court (1) failed to give 20 days’ notice before dismissing on grounds beyond the State’s motion, (2) applied an improper standard and relied on evidence outside the record, and (3) erred in finding counsel not ineffective.
- The Court of Appeals affirmed: notice was adequate because the court dismissed on grounds the State raised; Campbell’s and Archibald’s performance was not shown to be deficient given the record and applicable evidentiary rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Notice of dismissal under I.C. § 19-4906(b) | Bartell: district court dismissed on grounds beyond State's motion without 20 days’ notice | State: court relied on grounds asserted in State’s motion (failure to meet Strickland and evidentiary support) | Affirmed — notice satisfied because dismissal relied in part on grounds in State’s motion |
| Pretrial counsel failed to investigate mental-health / seek competency hearing | Bartell: Campbell should have contacted parents, obtained records, requested evaluation because of his mental disabilities | State/district court: no evidence Campbell knew or should have known of mental issues; record shows Bartell could assist in defense | Affirmed — no deficient performance shown; decision objectively reasonable |
| Trial counsel failed to present evidence of victims’ prior abuse by maternal relatives | Bartell: prior-abuse evidence could explain medical findings and fit Rule 412 exception; constitutional right to present full defense | State/district court: prior-abuse allegations were hearsay, irrelevant to the specific injuries, and would be excluded under I.R.E. 412 and 403 | Affirmed — evidence would have been inadmissible/irrelevant; counsel reasonably declined to present it |
| Reliance on facts outside the record / incorrect standard | Bartell: district court improperly relied on statements about counsel’s tactics and experience not in record and applied post-hoc standards | State/district court: strong presumption counsel acted reasonably; court’s inferences supported by uncontroverted record facts | Affirmed — no reversible error; court’s inferences permissible and supported by record conclusions about admissibility |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard: deficiency and prejudice)
- Kelly v. State, 149 Idaho 517 (notice requirement satisfied when court relies in part on State’s arguments)
- Saykhamchone v. State, 127 Idaho 319 (20-day notice required when court dismisses on its own initiative for grounds not raised by State)
- Begay v. United States, 937 F.2d 515 (10th Cir.) (prior sexual abuse admissible when it offers alternate explanation for injuries)
- LaJoie v. Thompson, 217 F.3d 663 (9th Cir.) (exclusion of prior-abuse evidence can violate right to present defense when highly probative of medical findings)
- Bouchillon v. Collins, 907 F.2d 589 (5th Cir.) (counsel aware of client’s significant mental-health issues; failure to pursue evaluation implicated ineffectiveness)
- Rhoades v. State, 148 Idaho 247 (post-conviction proceedings are civil; standard of proof and review on summary dismissal)
- Roman v. State, 125 Idaho 644 (petition must be supported by admissible evidence; court not required to accept conclusory allegations)