Robert Edward Sinn v. State of Iowa, 20-0127

Robert Sinn was convicted of third-degree sexual abuse after C.W. was found injured, naked from the waist down, with abrasions to her vaginal introitus; a rape kit was completed and C.W. reported possible vaginal penetration.
Sinn had been with C.W. after leaving a bar; witnesses observed Sinn wet, nervous, and giving varying accounts of the night; clothing and C.W.’s phone were recovered from Sinn’s car.
Officers Fowler and Deputy Bell questioned Sinn at a neighbor’s property (Roberts’s home); Sinn consented to retrieval of items from his vehicle; officers later searched the vehicle pursuant to a warrant and found C.W.’s underwear and other clothing.
Sinn made several statements to officers that changed over time; he was ultimately arrested and convicted; his conviction was affirmed on direct appeal.
Sinn sought postconviction relief alleging trial counsel was ineffective for failing to move to suppress his statements and vehicle evidence on Miranda/custody grounds; the district court denied relief and the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sinn was in "custody" during officers’ on-site questioning such that Miranda warnings were required, and whether counsel was ineffective for not moving to suppress.	Sinn: questioning was custodial at Roberts’s home; counsel breached duty by not moving to suppress; suppression would have excluded his statements and vehicle evidence and caused prejudice.	State: questioning occurred on open, familiar property; Sinn was free to leave, agreed to speak, and consented to search; Miranda warnings were not required; any suppression motion would be meritless.	Court: conversations were not custodial under the objective four-factor test; Miranda warnings were not required; counsel did not breach an essential duty by declining to file a meritless suppression motion; PCR denied.

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation triggers Miranda warnings requiring warning and waiver procedures)
State v. Countryman, 572 N.W.2d 553 (Iowa 1997) (four-factor objective test to determine custody for Miranda purposes)
State v. Schlitter, 881 N.W.2d 380 (Iowa 2016) (Miranda requires both custody and interrogation)
Ennenga v. State, 812 N.W.2d 696 (Iowa 2012) (ineffective-assistance claim requires proving breach of duty and prejudice)
State v. Gant, 597 N.W.2d 501 (Iowa 1999) (applicant must prove ineffective-assistance elements by a preponderance)
State v. Rice, 543 N.W.2d 884 (Iowa 1996) (no duty to file meritless suppression motion)
State v. Madsen, 813 N.W.2d 714 (Iowa 2012) (Strickland prejudice analysis in Iowa context)