Shawn Shelton v. Terry Mapes
2016 U.S. App. LEXIS 6416
| 8th Cir. | 2016Background
- In 1989 Shelton and passenger Swigart pursued/encountered Masters and Kennedy on a gravel road; Swigart fired a shotgun that killed Masters; Shelton later fired additional shots and admitted assembling the gun and saying “we have to kill them before they kill us.”
- Shelton was tried twice in Iowa state court; convicted at the second trial of first-degree murder (life) and attempted murder (25 years); state postconviction relief and appeals denied on ineffective-assistance claims.
- Shelton filed a federal habeas petition under 28 U.S.C. § 2254 asserting trial counsel was ineffective for failing to object to two jury instructions (Nos. 32 and 27) relating to justification and causation; district court denied relief and granted COA on ineffective-assistance issues.
- Instruction No. 32 told the jury that if Swigart was not justified, then Shelton was not justified; Iowa Court of Appeals found that statement erroneous as a matter of state law because justification is assessed individually.
- Instruction No. 27 misstated the record by saying the wound inflicted by the defendant resulted in Masters’ death (implying Shelton fired the fatal shot), whereas evidence showed Swigart fired the fatal shot.
- The federal appellate court reviewed Shelton’s ineffective-assistance claims under AEDPA/§2254(d) and Strickland prejudice standard, concluded the state court’s adjudication was not unreasonable, and affirmed denial of habeas relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Whether counsel was ineffective for not objecting to Jury Instruction No. 32 (justification) | Shelton: instruction wrongly tied his justification to Swigart’s state of mind, depriving him of a correct defense and of a fair trial | State: instruction error was against Iowa law but harmless given overwhelming evidence of non‑justification; no reasonable probability of different result | Court: No prejudice under Strickland; AEDPA deference means state court ruling not unreasonable; claim denied |
| 2. Whether counsel was ineffective for not objecting to Jury Instruction No. 27 (causation/factual error) | Shelton: instruction incorrectly stated Shelton inflicted fatal wound, misleading jury | State: factual error isolated; causation not contested; other instructions and evidence made the error harmless | Court: Error harmless under Strickland; no reasonable probability of different outcome; claim denied |
| 3. Whether combined instructional errors establish a constitutional violation | Shelton: cumulative effect of both errors deprived him of fair trial | State: Strickland does not permit aggregation of individually nonconstitutional errors to create constitutional violation | Court: No cumulative constitutional error; cannot combine harmless errors to reach constitutional magnitude |
| 4. Whether any remaining pro se claims warrant relief | Shelton (pro se): additional unspecified challenges | State: claims waived, moot, or without merit | Court: Pro se arguments considered and rejected as waived/moot/meritless |
Key Cases Cited
- Renico v. Lett, 559 U.S. 766 (AEDPA requires state-court error to be objectively unreasonable)
- Williams v. Taylor, 529 U.S. 362 (establishes "contrary to" and "unreasonable application" AEDPA standards)
- Strickland v. Washington, 466 U.S. 668 (two‑prong ineffective assistance of counsel test)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference; "no possibility fairminded jurists could disagree")
- Estelle v. McGuire, 502 U.S. 62 (federal habeas relief does not lie for state-law errors)
- Schriro v. Landrigan, 550 U.S. 465 (AEDPA standard and deference to state-court findings)