State of Iowa v. Marcos Fidel Castaneda
16-1303
| Iowa Ct. App. | Jul 19, 2017Background
- Defendant Marcos Fidel Castaneda was tried by jury and convicted of attempted murder for shooting Hugo Salinas twice on February 14, 2016.
- Evidence: Castaneda followed Salinas and his former girlfriend, parked, exited with a .22 rifle, shot Salinas in the chest, left, returned, and shot him in the head.
- The rifle required manual loading and manual unlocking for each shot; spent casing and an open box of .22 rounds were found in Castaneda’s vehicle.
- Jury was instructed the State must prove shooting, that Castaneda expected to set in motion events causing Salinas’ death, and that he specifically intended to cause Salinas’ death.
- Post-verdict, Castaneda appealed arguing (1) insufficient evidence of specific intent to kill and (2) trial court error in allowing an interpreter procured by the State to interpret without following court-rule appointment procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of intent to kill | State: facts support specific intent—two shots, targeted head and chest, manual loading shows deliberation | Castaneda: evidence insufficient to prove he specifically intended to cause death | Affirmed: substantial evidence supports specific intent |
| Improper procurement of interpreter | State: concedes rule not followed but argues no prejudice to defendant | Castaneda: prosecutor’s unilateral selection violated court rule and created appearance of impropriety; interpreter received trial materials | Affirmed: no prejudicial error—interpreter was Class A certified, received only publicly filed trial information, and had no prior contact with prosecutors |
Key Cases Cited
- State v. Sanford, 814 N.W.2d 611 (Iowa 2012) (standard for reviewing sufficiency of evidence)
- State v. Gansz, 376 N.W.2d 887 (Iowa 1985) (prejudice test for nonconstitutional error; prejudice presumed unless record establishes otherwise)
- State v. Cook, 565 N.W.2d 611 (Iowa 1997) (limitations on reading prejudicial allegations to jury)
- State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (ineffective-assistance claims need not be raised on direct appeal to preserve for postconviction relief)