State of Iowa v. Hillary Lee Hunziker, 20-0086

Background

Defendant Hillary Hunziker, with a documented history of mental-illness treatment, entered her ex-husband Jason’s home predawn, stabbed him about 20 times in a planned attack, took their child, and subsequently admitted to killing him; Jason died from severed major arteries.
Hunziker was arrested at her mother’s home, covered in blood, and made statements admitting the killing and describing perceived abuse of her son; she also reported hearing voices and suicidal ideation while in custody.
Hunziker was found competent to stand trial, asserted an insanity/diminished-capacity defense, and presented one psychiatric expert (Dr. Gratzer) who diagnosed psychosis/schizoaffective disorder; the State’s expert (Dr. Lestina) diagnosed personality, mood, anxiety, and substance disorders and concluded Hunziker understood the legal wrongfulness of her acts.
Defense expert became unavailable for the set trial date due to a scheduling miscommunication; the court denied a continuance but allowed the defense expert to testify by video deposition (agreed by both sides).
At trial the court modified the uniform insanity jury instruction to emphasize the defendant’s ability to distinguish legally right from legally wrong (not moral right/wrong); Hunziker objected.
Hunziker sought substitute counsel twice; the court denied both motions after (limited) inquiry. She was convicted of first-degree murder, sentenced to life without parole, and appealed raising multiple claims.

Issues

Issue	State's Argument	Hunziker's Argument	Held
Denial of continuance for unavailable defense expert	Court did not abuse discretion; alternative (video deposition) preserved defendant’s rights and avoided undue delay	Denial was prejudicial because video deposition impaired jury’s ability to assess witness credibility; continuance was necessary	No abuse of discretion; video deposition adequate and no injustice resulted (continues to trial)
Jury instruction deviation on insanity (legal vs moral wrong)	Modified instruction correctly stated Iowa law focusing on legal wrongness; deviation permissible and did not misstate law	Modification misstated law and prevented jury from considering defendant’s moral delusion defense	Instructions accurate under Iowa precedent; emphasizing legal (not moral) wrongness was proper and not reversible error
Weight/sufficiency of evidence re: insanity defense	Evidence (including experts) showed Hunziker understood her acts were legally wrong; verdict supported by weight of evidence	Evidence of psychosis and delusion proved insanity and verdict was against the weight of evidence	Denial of new trial affirmed; evidence did not preponderate against the verdict—insanity not proven by preponderance
Motions for substitute counsel / court inquiry	Court adequately inquired on second motion and discretionarily denied substitute counsel; no showing of actual conflict or breakdown impairing adversarial process	Court failed to inquire sufficiently on initial pro se conflict claim and later counsel breakdown warranted substitution	No reversal: initial pro se allegation should have prompted inquiry but remand unnecessary; second motion inquiry was adequate and no breakdown or actual conflict shown
Ability to raise ineffective-assistance claim on direct appeal (Iowa Code §814.7) / plain-error request	Section 814.7 bars raising ineffective-assistance claims on direct appeal; constitutional challenges to statute fail under controlling precedent	Denial of direct-review of ineffective-assistance claim violates separation of powers, due process, and equal protection; requests plain-error review	Court follows controlling Iowa Supreme Court precedent: §814.7 constitutional as applied (no plain-error adoption); ineffective-assistance claim preserved for postconviction relief only

Key Cases Cited

State v. Artzer, 609 N.W.2d 526 (Iowa 2000) (continuance standard; abuse of discretion review)
State v. Shorter, 945 N.W.2d 1 (Iowa 2020) (review of jury-instruction errors)
State v. Hamann, 285 N.W.2d 180 (Iowa 1979) (M'Naghten/insanity inquiry refers to legal right and wrong)
State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (insanity test focus on legal understanding)
State v. Hatter, 414 N.W.2d 333 (Iowa 1987) (permissible deviations from uniform instructions when they do not change the crime definition)
Cuyler v. Sullivan, 446 U.S. 335 (U.S. 1980) (trial court’s duty to inquire where conflicts of counsel may exist)
State v. Tejeda, 677 N.W.2d 744 (Iowa 2004) (standard for inquiry on request for substitute counsel)
State v. Powell, 684 N.W.2d 235 (Iowa 2004) (need for court inquiry into alleged conflict and remedy where failure occurs)
State v. Lopez, 633 N.W.2d 774 (Iowa 2001) (breakdown-in-communication standard and sufficiency of trial court inquiry)
State v. Treptow, 960 N.W.2d 98 (Iowa 2021) (treatment of §814.7 and standards for ineffective-assistance claims on direct appeal)
State v. Tucker, 959 N.W.2d 140 (Iowa 2021) (§814.7 does not violate separation-of-powers)
State v. Damme, 944 N.W.2d 98 (Iowa 2020) (application of amended §814.7 to judgments entered on or after July 1, 2019)