State of Iowa v. Johnny Ahman Madison, 15-2069

State trooper stopped vehicle driven by Johnny Madison; search uncovered marijuana on center console, residue in back seat, and two bags inside Madison’s shoes.
Madison was charged with possession of a controlled substance (marijuana), first offense, and convicted by a jury.
Trial court gave a standard possession instruction defining both actual and constructive possession and stating "possession includes actual as well as constructive possession."
Madison’s trial counsel did not object to the inclusion of "actual possession" in the jury instruction.
On appeal Madison argued counsel was ineffective for failing to object because the evidence allegedly did not support actual possession.
The State argued, and the prosecutor emphasized at closing, that only constructive possession was at issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to object to inclusion of "actual possession" in the jury instruction	The State relied on standard instruction; prosecutor prosecuted constructive possession	Madison: evidence did not support actual possession, so instruction should not have included that term; counsel had duty to object	No ineffective assistance: even assuming instruction was unsupported as to actual possession, prosecutor expressly limited theory to constructive possession at closing, so no prejudice under Strickland
Whether other potential ineffective-assistance claims should be addressed on direct appeal	State: record is adequate only for the raised claim; other claims can be preserved	Madison: requests preservation/consideration of any additional claims not apparent in record	Court declined to act; such claims need not be raised on direct appeal and may be pursued in postconviction relief

State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (court should not give instruction unsupported by evidence)
Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance test: deficiency and prejudice)
State v. Harris, 891 N.W.2d 182 (Iowa 2017) (prejudice standard quotation applying Strickland)
State v. Reynolds, 746 N.W.2d 837 (Iowa 2008) (discussion of reasonable-probability prejudice)
State v. Virgil, 895 N.W.2d 873 (Iowa 2017) (preservation of ineffective-assistance claims for PCR proceedings)
State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (no Strickland prejudice where prosecutor removed an alternative from jury consideration)