Michael E. Hilson, Applicant-Appellant v. State of Iowa, 15-0679

In Sept. 2006 T.B. reported she had been raped; officer and sexual-assault nurse responded and a rape kit was collected. T.B. died later that year in an unrelated accident.
The rape kit was sent to the DCI in 2008; DNA testing linked Michael Hilson to the kit. He was charged with burglary and sexual-abuse offenses and convicted; convictions were affirmed on direct appeal.
Hilson filed a pro se postconviction-relief (PCR) application in 2013 raising, among other claims, ineffective assistance of trial counsel for inadequate investigation and failure to use an expert.
At the PCR hearing, trial counsel had testified he took at least ten depositions, used a private investigator, pursued independent DNA testing at multiple labs, and declined to present an alibi witness whose credibility he doubted.
The PCR court denied relief, finding counsel’s investigation and decisionmaking reasonable and that Hilson failed to show prejudice because Hilson’s DNA was found in the victim and additional testing or witnesses were unlikely to change the outcome.
This appeal presents only the ineffective-assistance claims (investigation/alibi witnesses and failure to retain an expert); the court affirms the PCR denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Counsel failed to adequately investigate alibi/exculpatory witnesses	Hilson: counsel should have done more investigation and called an alibi witness and others who might support an alternate perpetrator theory	State: counsel conducted extensive investigation (depositions, PI work) and reasonably chose not to present weak or unreliable witnesses	Held: No duty breached; counsel’s investigation was reasonable and Hilson showed no prejudice
Counsel failed to retain/consult an expert to test stains and items from the apartment	Hilson: wanted all items tested to determine if stains were blood or from another perpetrator (e.g., Kool-Aid)	State: counsel obtained independent DNA testing by multiple labs and reasonably concluded further testing would add little value and would waste resources/delay trial	Held: No ineffective assistance — additional testing would not raise a reasonable probability of a different result given Hilson’s DNA in the victim

Castro v. State, 795 N.W.2d 789 (Iowa 2011) (standard of review for PCR proceedings)
Tompkins v. State, 859 N.W.2d 631 (Iowa 2015) (de novo review and two-prong test for ineffective assistance)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (counsel must conduct reasonable investigation; not required to interview every potential witness)
Ambrose v. State, 861 N.W.2d 550 (Iowa 2015) (ineffective-assistance claims may be resolved on either deficient-performance or prejudice prong)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance standard: deficient performance and reasonable probability of different outcome)