Lynn G. Lamasters Vs. State of Iowa, 2012 Iowa Sup. LEXIS 94

Lamasters was convicted of first‑degree murder in 2005 and sought postconviction relief in 2009 alleging ineffective assistance of trial and appellate counsel.
The postconviction court denied relief; the court of appeals affirmed, holding preservation issues incomplete, but we review de novo for ineffective assistance.
Lamasters claimed trial counsel failed to pursue temporary insanity/diminished capacity and failed to support a bifurcation of guilt and insanity; appellate counsel allegedly failed to appeal the denial of bifurcation.
The district court denied postconviction relief after hearing testimony and evidence, including Dr. Gratzer’s psychiatric evaluations; the appellate court later addressed preservation and merits.
At issue on appeal is whether trial/appellate counsel’s claims were preserved and, on the merits, whether any ineffective assistance affected the trial’s outcome.
The majority ultimately affirms the district court’s denial of postconviction relief, concluding no reasonable probability of an insanity or diminished-capacity defense or effective bifurcation, given the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Error preservation for postconviction claims	Lamasters preserved error per district court ruling acknowledging the issues.	District court failed to rule on claims; error not preserved under Rule 1.904(2).	Error preserved; district ruling considered the issues.
Failure to raise temporary insanity/diminished capacity	Trial counsel should have pursued insanity or diminished capacity defenses.	Insanity/diminished capacity lacked expert support; not reasonably probable to succeed.	No reasonable probability the defense would have changed outcome.
Failure to sufficiently support bifurcation	Counsel failed to provide strong bifurcation basis, potentially triggering a separate insanity phase.	Bifurcation denied due to lack of inculpatory admissions; Jenkins governs standard.	No reasonable probability bifurcation would have altered verdict.
Appellate counsel ineffective re bifurcation on appeal	Appellate counsel should have challenged the denial of bifurcation on direct appeal.	Record showed district court denied bifurcation; appeal record insufficient to prove error.	Not entitled to relief; appellate failure to raise the issue did not prejudice outcome.

Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (preservation requires the district court to decide the issue; mislabeling as a rule 1.904(2) motion still preserves if court ruled on the issue)
Jenkins, 412 N.W.2d 174 (Iowa 1987) (bifurcation standards and admissibility of psychiatric testimony under bifurcation rules)
Collins, 236 N.W.2d 376 (Iowa 1975) (insanity defense and psychiatric examination limitations; fifth-amendment concerns)
Anfinson v. State, 758 N.W.2d 496 (Iowa 2008) (diminished capacity defense; specific-intent considerations)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (standard for evaluating ineffective assistance claims on appeal or postconviction)
Strickland v. Washington, 466 U.S. 668 (1984) (establishing performance and prejudice prongs for ineffective assistance)