State of Iowa v. Joseph William Rendon, 15-1832

Background

On Sept. 24–25, 2014, an armed group robbed players at an illegal high‑stakes poker game in Johnston, Iowa; the robbers fled in a Chevrolet Impala and were followed by a maroon SUV.
Police recovered Impala paperwork with Moore’s name, fingerprints of Thompson and Jacari, Thompson’s DNA on a mask, and cell‑phone records showing communications among Rendon, Thompson, Moore, and Jacari.
Witnesses (Moore, Thompson, Jacari) testified Rendon planned or assisted the robbery (providing the idea, gloves, zip ties, and driving a maroon SUV); Thompson and Moore entered plea/proffer agreements.
Detective Tompkins testified as an expert interpreting cell‑tower/call records linking defendants’ locations and contacts; Detective Nore introduced a Facebook photo later shown to have an incorrect UTC timestamp.
Rendon was convicted of first‑degree burglary and nine counts of first‑degree robbery; he appealed raising: admission of drug‑dealing evidence, expert qualification, sufficiency/corroboration of accomplice testimony, and ineffective assistance of counsel.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of evidence of Rendon’s drug dealing	State: drug evidence was relevant to show relationship, motive, and plan	Rendon: prior bad acts evidence was prejudicial and beyond permissible scope	Court: Error not preserved on general admissibility (no timely objection); even on merits evidence admissible for motive/plan and not substantially more prejudicial
Motion for mistrial based on drug‑deal testimony	State: testimony was permissible to show plan/motive; prosecutor ceased improper questioning when objected	Rendon: prosecutor elicited excessive drug‑related testimony causing undue prejudice	Held: district court did not abuse discretion denying mistrial
Qualification of detective as expert on cell‑phone records	State: Tompkins had training/experience to interpret records and assist jury	Rendon: Tompkins’ training was outdated; testimony should be excluded	Held: admissible; any currency issue goes to weight, not admissibility
Sufficiency / corroboration of accomplice testimony	State: independent corroboration existed (video of maroon SUV, stop on I‑80, cell records, paperwork in Impala)	Rendon: convictions rested only on accomplice testimony without corroboration	Held: corroboration sufficient; issue not preserved in motion for acquittal, and in any event evidence tended to connect Rendon
Ineffective assistance of counsel (multiple grounds)	State: counsel’s omissions (not objecting to facebook photo timing, certain cell‑phone testimony, failing to raise corroboration) were either harmless or would have failed	Rendon: counsel failed essential duties causing prejudice	Held: defendant failed to prove deficient performance or prejudice; many objections would have been meritless

Key Cases Cited

State v. Alberts, 722 N.W.2d 402 (Iowa 2006) (finality of pretrial rulings and preservation requirements)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (standard for mistrial review)
State v. Hicks, 791 N.W.2d 89 (Iowa 2010) (abuse of discretion review for expert testimony)
State v. Tyler, 867 N.W.2d 136 (Iowa 2015) (liberal admissibility of expert testimony under Iowa R. Evid. 5.702)
State v. Serrato, 787 N.W.2d 462 (Iowa 2010) (standard for reviewing motions for judgment of acquittal)
Ennenga v. State, 812 N.W.2d 696 (Iowa 2012) (de novo review of ineffective‑assistance claims)
State v. Carroll, 767 N.W.2d 638 (Iowa 2009) (two‑part ineffective‑assistance test)
State v. McKettrick, 480 N.W.2d 52 (Iowa 1992) (defendant’s burden in ineffective‑assistance claims)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (prejudice standard for counsel error)
State v. Lopez, 872 N.W.2d 159 (Iowa 2015) (no deficiency when objection would be meritless)
State v. Douglas, 675 N.W.2d 567 (Iowa 2004) (accomplice testimony cannot alone support conviction)
State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (corroboration need only tend to connect defendant to crime)
State v. Wilson, 878 N.W.2d 203 (Iowa 2016) (Rule 5.404(b) framework and balancing test)
State v. Crawley, 633 N.W.2d 802 (Iowa 2001) (prior drug activity admissible to show motive)
State v. Putnam, 848 N.W.2d 1 (Iowa 2014) (requirement of clear proof before admitting evidence of prior bad acts)
Leaf v. Goodyear Tire & Rubber Co., 590 N.W.2d 525 (Iowa 1999) (Daubert analysis not required in Iowa for non‑novel expert matters)