State of Iowa v. James Norman Harris, 2017 Iowa Sup. LEXIS 18

Late-night pool-bar altercation in Sioux City: Harris and Niles argued inside, left the bar, and shortly thereafter Niles was stabbed multiple times outside.
Bartender saw Harris holding a knife during the fight; medical evidence showed multiple knife wounds consistent with an attack.
Harris was charged with going armed with intent (Iowa Code § 708.8) and willful injury causing bodily injury; convicted of going armed with intent and a lesser-included aggravated misdemeanor for the other count.
At trial defense counsel moved for judgment of acquittal but did not specifically challenge the evidence of movement (the "going" element) and did not object to the marshalling instruction, which omitted the element of movement.
On appeal Harris argued counsel was ineffective for failing to (1) challenge sufficiency of evidence on the movement element and (2) object to the jury instruction omitting that element.
Iowa Supreme Court: held counsel was not ineffective for failing to challenge sufficiency (substantial circumstantial evidence of movement existed) but was ineffective for failing to object to the flawed instruction; reversed the going-armed conviction and remanded for a new jury trial on that count.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Harris)	Held
Sufficiency of evidence for the "going" (movement) element of going armed with intent	Evidence (knife seen, wounds, timing/location) supports finding Harris moved while armed; conviction should stand	Evidence did not show Harris carried the knife while moving from inside to outside; counsel should have challenged sufficiency	Counsel not ineffective for failing to move for acquittal on "going"; substantial circumstantial evidence supported movement
Failure to object to jury instruction that omitted the movement element	Omission likely a breach but no prejudice because evidence of movement was sufficient	Omission deprived jury of required element; counsel ineffective for not objecting; conviction should be reversed	Counsel breached duty by not objecting; omission undermined confidence in verdict—prejudice shown; conviction reversed and remanded for retrial on that count

State v. Ray, 516 N.W.2d 863 (Iowa 1994) (defines "armed" and recognizes "going" requires movement)
State v. Pearson, 804 N.W.2d 260 (Iowa 2011) (instructional omission of movement element requires a new trial when preserved)
State v. Horness, 600 N.W.2d 294 (Iowa 1999) (preservation rules and reviewing ineffective-assistance claims on direct appeal)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel)