State of Iowa v. Eric Thompson, 14-0560

On July 4, 2013, Eric Thompson led police on a vehicle and foot chase; officers later searched his car and found items (propane tank with tubing, drain cleaner, salt, coffee filters, containers and residues) suggesting methamphetamine manufacture.
After arrest, officers found two small plastic bags (one testing positive for pseudoephedrine) and two lithium batteries on Thompson.
At trial, the State introduced a National Precursor Log Exchange printout listing Thompson’s pseudoephedrine purchases over the prior seven months; the district court admitted the printout over Thompson’s relevance objection.
An officer then testified, without objection, in detail about the purchases and attempted purchases reflected on the database printout.
The jury convicted Thompson of manufacturing methamphetamine, possession of precursors (ephedrine/pseudoephedrine and lithium) with intent to manufacture, and eluding; he admitted being an habitual offender and was sentenced.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior pseudoephedrine purchases	Printout is relevant to intent and practice of manufacturing; admissible	Purchases are not relevant or are unduly prejudicial	Even if admission of the printout was error, admission was harmless because an officer testified in detail about the same purchases without objection; no reversible error
Ineffective assistance of counsel	Not asserted by State on appeal	Trial counsel provided ineffective assistance (claimed)	Claim preserved for postconviction relief because the appellate record is inadequate to resolve the ineffective-assistance claim now

State v. Rodriguez, 636 N.W.2d 234 (Iowa 2001) (standard of review for evidentiary rulings)
Graber v. City of Ankeny, 616 N.W.2d 633 (Iowa 2000) (two-step relevancy and prejudice inquiry)
State v. Trudo, 253 N.W.2d 101 (Iowa 1977) (no prejudice where same evidence otherwise in record)
State v. Jurgenson, 225 N.W.2d 310 (Iowa 1975) (error in admission not prejudicial when substantially same evidence is in the record)
Estrella v. State, 133 N.W.2d 97 (Iowa 1965) (order of testimony immaterial when substance is substantially the same)
In re Estate of Hettinga, 514 N.W.2d 727 (Iowa Ct. App. 1994) (cumulative evidence that corroborates other properly admitted evidence is not reversible error)
State v. Willis, 696 N.W.2d 20 (Iowa 2005) (ineffective-assistance claims reviewed de novo and normally preserved for postconviction relief)
State v. Rubino, 602 N.W.2d 558 (Iowa 1999) (trial tactics often require a developed record for ineffective-assistance review)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (preservation and procedure for raising ineffective-assistance claims)