State of Iowa v. Jayden Ray Chapman
15-1078
| Iowa Ct. App. | Dec 21, 2016Background
- On March 10, 2014, Jayden Chapman, Michael Schenk, and Erika Dains, after using methamphetamine, went to Marvin Huelsing’s farm to steal scrap metal; a confrontation followed in which both Huelsing and Alice Huisenga were shot and a mobile home and pickup were set on fire.
- Chapman admitted involvement: he helped search the trailer, armed himself with a knife, handled ammunition, admitted shooting at Huisenga, returned a gun to Schenk, and participated in concealing items and setting fires. Physical evidence (a rifle with Huelsing’s blood, clothing with Chapman’s DNA, gas cans) linked Chapman to the scene.
- Dains and other witnesses testified about Chapman’s and Schenk’s conduct before, during, and after the killings, including statements that Schenk had said “if people come, we’ll kill them,” Chapman’s suggestion to “get rid of” the small truck, and Chapman’s later admission “we set the fire.”
- A jury convicted Chapman of two counts of first-degree murder and one count of reckless use of fire (lesser-included of arson). Chapman moved for new trial and in arrest of judgment; both denied. He was sentenced to life without parole on each murder count and one year for reckless use of fire.
- Chapman appealed, arguing (1) ineffective assistance for failing to object to jury instructions (aiding-and-abetting/malice), (2) insufficiency of the evidence (specific intent and aiding/abetting), and (3) that the verdict was contrary to the weight of the evidence.
Issues
| Issue | Chapman’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not objecting to jury instructions that (allegedly) failed to require proof Chapman knew principal’s malice aforethought | Jury instructions should have required proof Chapman had malice aforethought or knew the principal had malice aforethought before convicting as aider/abettor | Instructions properly required proof of specific intent to kill or knowledge that the principal had specific intent; specific intent implies malice aforethought here | No ineffective assistance; instructions on specific intent were sufficient and linked to malice where appropriate |
| Whether Chapman showed prejudice from counsel’s alleged failure to object | Even if instructions were erroneous, Chapman would have been prejudiced and outcome could differ | Ample evidence Chapman knew Schenk’s intent and participated; no reasonable probability of different outcome | No prejudice shown; ineffective-assistance claim fails on prejudice ground |
| Whether evidence was insufficient to support first-degree murder convictions (specific intent, aiding/abetting) | Methamphetamine intoxication impaired Chapman’s capacity to form specific intent; evidence only shows involvement in theft | Testimony, Chapman’s admissions, physical and forensic evidence, and conduct before/during/after the killings support either principal or aider/abettor liability and capacity to form intent | Substantial evidence supports convictions for both murders as principal or aider/abettor |
| Whether conviction for reckless use of fire and verdicts were contrary to the weight of evidence (motion for new trial) | Insufficient evidence linking Chapman to setting/encouraging the fires; overall weight of evidence favors acquittal | Dains’s testimony, Chapman’s statements ("we set the fire", "get rid of the truck"), gasoline odors, and coordinated cover-up establish aiding/abetting reckless use of fire; record does not preponderate against verdict | Conviction for reckless use of fire supported; district court did not abuse discretion denying new trial; verdict not contrary to weight of evidence |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance standard: deficient performance and prejudice)
- State v. Clay, 824 N.W.2d 488 (Iowa 2012) (ineffective-assistance review de novo; prejudice analysis)
- State v. Tangie, 616 N.W.2d 564 (Iowa 2000) (aider-and-abettor liability: participant may be convicted by acting with requisite intent or knowing the principal possessed it)
- State v. Ceretti, 871 N.W.2d 88 (Iowa 2015) (distinguishing malice aforethought from specific intent to kill; specific intent implies malice)
- State v. Bogan, 774 N.W.2d 676 (Iowa 2009) (discussion of jury-instruction issues; noted need to instruct on knowledge of malice but did not analyze the issue fully)
- State v. Tyler, 873 N.W.2d 741 (Iowa 2016) (standards for reviewing sufficiency of evidence and aiding/abetting principles)