Samuel Montez Wright, Applicant-Appellant v. State of Iowa, 15-1530

Background

On January 15–17, 2008 Zachary Cooper was robbed, kidnapped and shot; his frozen, shirtless body was found near Lawton, Iowa. Wright was tried, convicted of first‑degree murder, first‑degree kidnapping, and first‑degree robbery, and sentenced to life plus terms for other counts.
State witnesses (Perez and Dukes) testified Wright and Williams restrained Cooper, drove him to a rural site, and both Wright and Williams shot Cooper; physical evidence included Cooper’s blood in the rear seat and .380 ammunition linked to Wright’s apartment.
Wright denied presence at the murder on trial and gave inconsistent statements to police and at trial; he testified an alibi and alternative explanations for phone/location and ammunition evidence.
After conviction and direct appeal, Wright sought postconviction relief (PCR) based on newly discovered statements (depositions) in which Dukes purportedly admitted shooting Cooper, and various claims of ineffective assistance of trial counsel.
The PCR court denied relief; on appeal the Iowa Court of Appeals reviewed newly discovered evidence and multiple ineffective‑assistance claims and affirmed the denial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Newly discovered evidence (Dukes’s alleged recantation/admissions)	Dukes later told third parties he shot Cooper; this new evidence would probably change the verdict or at least require accomplice instruction	State: recantations are suspicious, depositions were from jailed witnesses, and admissions do not clear Wright; even if Dukes shot, evidence still implicates Wright	Denied — court found recantations suspect, would not probably change outcome; they do not exonerate Wright or undermine corroboration of accomplice testimony
Accomplice‑corroboration instruction	Wright argued Dukes’s statements would have compelled giving accomplice instruction or changed result	State: prior appellate panel already found corroboration sufficient; Dukes’s later statements don’t undercut corroborating evidence	Denied — prior analysis stands; corroborating evidence (cell‑site, blood, eyewitnesses, ammunition) would still support verdict
Ineffective assistance — jury instruction on kidnapping (omitted Rich test)	Trial counsel breached duty by not objecting to a kidnapping instruction that omitted the Rich tripartite removal test	State: error occurred but must show Strickland prejudice considering cumulative errors	Trial counsel breached duty by not objecting, but Wright failed to prove prejudice when viewing totality of evidence
Ineffective assistance — failure to object to gang‑membership testimony	Counsel should have objected to testimony that Wright was an “inactive” gang member (prior bad act)	State: minimal, isolated testimony and Wright denied gang ties; probative value low and not highly prejudicial	Breach found (counsel should have objected), but isolated remark did not produce Strickland prejudice when considered with overall evidence

Key Cases Cited

Millam v. State, 745 N.W.2d 719 (Iowa 2008) (standard of review for PCR and ineffective‑assistance claims)
More v. State, 880 N.W.2d 487 (Iowa 2016) (standards for newly discovered evidence in PCR)
Jones v. State, 479 N.W.2d 265 (Iowa 1991) (recantation testimony viewed with skepticism)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑pronged ineffective assistance standard)
State v. Rich, 305 N.W.2d 739 (Iowa 1981) (test for when removal or confinement exceeds incidents of underlying crime for kidnapping)
State v. Doughty, 359 N.W.2d 439 (Iowa 1984) (defendant entitled to instruction defining required removal for kidnapping)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (evaluate cumulative Strickland prejudice)
State v. Putman, 848 N.W.2d 1 (Iowa 2014) (prior‑bad‑acts admissibility framework)