Larry Wayne Steen, Applicant-Appellant v. State of Iowa
16-1140
| Iowa Ct. App. | Sep 13, 2017Background
- On Sept. 24, 2010, Larry Steen shot and killed Randy Saner in the home of Steen’s ex-wife, Cathy Clark. Steen was convicted of second-degree murder.
- Steen asserted at trial a “go-for-broke” defense claiming Clark committed the murder and framed him; he rejected an intoxication/diminished-capacity defense because it would require admitting he caused the death and likely lead to a long prison sentence.
- Trial counsel strategically pursued complete innocence, partly to exploit community rumors implicating Clark and to avoid confusing the jury with inconsistent defenses.
- Steen was convicted on Oct. 11, 2011; the conviction was affirmed on direct appeal.
- Steen filed a postconviction-relief (PCR) application claiming trial counsel was ineffective for failing to present evidence or pursue a manslaughter theory; the district court denied relief and Steen appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not presenting a manslaughter theory | Steen: counsel should have developed and presented manslaughter/diminished-capacity evidence, which could have led to a lesser verdict | State: counsel made a reasonable, strategic decision (with Steen’s agreement) to pursue complete-innocence theory and avoid inconsistent defenses | Court: Counsel was effective; strategic decision reasonable and not deficient |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes the two-part ineffective-assistance-of-counsel test: deficiency and prejudice)
- Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (ineffective-assistance claims reviewed de novo; two-prong test applied)
- McLaughlin v. State, 533 N.W.2d 546 (Iowa 1995) (standard of review for PCR denials and de novo review for constitutional claims)
- Jones v. State, 479 N.W.2d 265 (Iowa 1991) (burden to prove ineffective assistance by a preponderance of the evidence)
- State v. Polly, 657 N.W.2d 462 (Iowa 2003) (trial strategy decisions after thorough investigation are virtually unchallengeable)