Kenneth Leroy Adams v. State of Iowa, 20-0807

Background

Kenneth Adams was convicted of child endangerment resulting in death after admitting in recorded interviews he placed an 18‑month‑old face‑down on a pillow and restrained the child until breathing slowed; the child later died.
The State medical examiner testified the cause of death was suffocation and the manner homicide, based on autopsy findings, elimination of other causes, a reenactment video, and Adams’s statements.
Trial counsel did not move to exclude the medical examiner’s opinion, did not request a mistrial after the examiner made disparaging remarks about defense counsel during cross, and declined to request a jury instruction that no inference be drawn from Adams’s choice not to testify.
Adams raised ineffective‑assistance claims in a postconviction relief (PCR) application; the parties submitted a stipulated record and the PCR court denied relief. Adams appeals.
On appeal the court reviewed ineffective‑assistance claims de novo, declined to consider a new claim that the examiner relied improperly on police information because it was not preserved, and affirmed the PCR denial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial counsel ineffective for failing to exclude medical examiner's cause/manner testimony (Daubert/Ranes challenge)	Adams: counsel should have objected; testimony lacked scientific basis and was speculative, so inadmissible under Daubert/Ranes.	State: Iowa applies a liberal admissibility rule; ME was qualified, testimony relevant, grounded in autopsy, experience, reenactment and elimination of other causes; objection would fail.	Held: No breach. Testimony admissible under Iowa law; raising a meritless objection not required.
Trial counsel ineffective for failing to move for a mistrial after ME's disparaging comments about counsel's knowledge of copyright law	Adams: ME's comments undermined counsel's credibility; a mistrial should have been sought.	State: Comments were disrespectful but not substantive, not a competency attack warranting mistrial; counsel reasonably declined to seek mistrial.	Held: No breach. Comments were not grounds for mistrial; counsel's tactical decision reasonable.
Trial counsel ineffective for failing to request instruction that no inference may be drawn from defendant's failure to testify	Adams: such an instruction would prevent jurors from inferring guilt from silence.	State: Counsel strategically declined because defense relied on recorded statements as plaintiff's testimony; Esse limiting instruction and strategy made requesting the instruction counterproductive.	Held: No breach. Tactical decision consistent with defense theory; reasonable strategy.
Preservation: claim that ME relied largely on law‑enforcement statements (Tyler)	Adams: ME’s opinion was impermissibly based on police statements and should have been excluded.	State: That specific Tyler argument was not raised below, so it is waived.	Held: Not considered on appeal—issue not preserved for PCR or appeal.

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance of counsel).
Ranes v. Adams Labs., Inc., 778 N.W.2d 677 (Iowa 2010) (Iowa's liberal approach to expert admissibility under Iowa R. Evid. 5.702).
Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993) (federal admissibility standard for expert testimony).
State v. Tyler, 867 N.W.2d 136 (Iowa 2015) (medical‑examiner opinions may be impermissible if based largely on police statements).
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (applying Strickland in Iowa PCR context).
Ledzema v. State, 626 N.W.2d 134 (Iowa 2001) (prejudice standard and counsel competence presumption).
Leaf v. Goodyear Tire & Rubber Co., 590 N.W.2d 525 (Iowa 1999) (Iowa has not fully adopted Daubert).
State v. Brubaker, 805 N.W.2d 164 (Iowa 2011) (presumption of competent performance; avoid hindsight review).
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issues must be raised and decided below to be considered on appeal).
State v. Virgil, 895 N.W.2d 873 (Iowa 2017) (instructional error assessed in light of defense theory).