State of Iowa v. K'von James Henderson, 16-0575

On Feb 10, 2015, Henderson and four others planned and executed a robbery of Greenwood Pharmacy; two entrants demanded drugs and money while others served as getaway drivers.
A handgun was produced during the robbery and the pharmacist complied; two participants were arrested near the store; Henderson was not arrested there but later was at the co-defendant Nelson’s residence where robbery proceeds were divided.
Nelson testified Henderson received and pocketed some of the stolen drugs; Henderson’s cell phone records showed calls among participants immediately before the robbery; a tinfoil package of Xanax was found on Henderson.
Henderson was tried with co-defendants, convicted of first-degree robbery (claimed dangerous-weapon enhancement), and appealed claiming insufficient evidence and ineffective assistance of counsel (pro se brief raised additional claims).
The court treated accomplice corroboration, sufficiency, and multiple ineffective-assistance claims, affirmed the conviction, and found the record adequate to resolve the IAC claims on direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence / accomplice corroboration	State: Nelson’s testimony was corroborated by phone records, presence at Nelson’s house, possession of stolen Xanax, and other witness testimony	Henderson: accomplice testimony lacked corroboration tying him to the robbery	Held: Evidence sufficiently corroborated accomplice testimony; conviction upheld
Dangerous-weapon element preservation	State: Dismissal for acquittal motion did not raise weapon issue so error not preserved	Henderson: argued insufficient evidence that he knew a dangerous weapon would be used	Held: Weapon issue not preserved for appeal; alternatively, as aider/abettor Henderson is liable and record shows a police-style handgun was used
Ineffective assistance — voir dire record	State: No record of voir dire was made so no basis to show counsel ineffective	Henderson: counsel waived voir dire reporting, depriving him of challenge	Held: Waiver of reporting voir dire prevents review; claim waived
Ineffective assistance — other trial-strategy complaints (motion in limine, failure to depose witness, failure to object to evidence)	State: Counsel made strategic choices, objections were made where appropriate; record does not show prejudice	Henderson: counsel failed to preserve/explore exculpatory statements, depose witnesses, and object to certain evidence	Held: Court found no deficient performance or resulting prejudice on these claims; no relief granted

State v. Krogman, 804 N.W.2d 518 (Iowa 2011) (error-preservation requires timeliness and specificity)
State v. Williams, 695 N.W.2d 23 (Iowa 2005) (exceptions to specificity requirement when grounds are obvious and element totally unproven)
State v. Showens, 845 N.W.2d 436 (Iowa 2014) (review standard for sufficiency: view evidence in light most favorable to State)
State v. Berney, 378 N.W.2d 915 (Iowa 1985) (accomplice corroboration need not be strong; must fairly connect defendant to offense)
Fountain v. State, 786 N.W.2d 260 (Iowa 2010) (ineffective-assistance claims present an exception to traditional error-preservation rules)
Lemasters v. State, 821 N.W.2d 856 (Iowa 2012) (de novo review of constitutional IAC claims)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (two-prong Strickland framework applied in Iowa: duty and prejudice)
Tyler v. State, 352 N.W.2d 683 (Iowa 1984) (presumption counsel competent)
Artzer v. State, 609 N.W.2d 526 (Iowa 2000) (direct appeal may resolve IAC when record adequate)
Dunbar v. State, 515 N.W.2d 12 (Iowa 1994) (claimant must show how competent representation probably would have changed outcome)