State of Iowa v. Miguel Angel Lorenzo Baltazar, 935 N.W.2d 862

On July 28, 2017 Jeffrey Mercado was shot and killed; ballistic and DNA evidence tied a recovered semiautomatic handgun to Miguel Baltazar, who was arrested fleeing the scene.
Witness Anthony Garcia testified he drove Baltazar to find Mercado, watched Baltazar exit the car and shoot Mercado multiple times, then crash and flee; Garcia admitted prior discussions about confronting Mercado.
Baltazar testified he grabbed a handgun to ‘‘get Mercado’s attention,’’ claimed he fired at the ground to scare Mercado, and asserted self-defense/defense-of-others.
The jury was given an outdated justification (self-defense/retreat) instruction that included an "alternative course of action" duty to retreat; defense counsel did not object.
The jury convicted Baltazar of first-degree murder and the district court sentenced him to life; on appeal Baltazar argued ineffective assistance for failing to object to instructions and that the court erred in excluding two videos of the victim’s prior violent acts.
The Iowa Supreme Court affirmed the conviction: it held counsel was not ineffective because Baltazar was engaged in illegal activity (possession/use of a handgun germane to the shooting) so the stand-your-ground provision did not apply, and it upheld exclusion of the videos because Baltazar did not know of those specific prior incidents.

Issue	Baltazar's Argument	State's Argument	Held
Whether defense counsel’s failure to object to an outdated justification (retreat) instruction constituted ineffective assistance	Counsel breached an essential duty by not objecting; the 2017 amendment (stand-your-ground) eliminated any duty to retreat and the jury was misinstructed	Counsel had no duty to object because Baltazar was engaged in illegal activity (carrying/using a handgun relevant to the shooting), so stand-your-ground did not apply	Counsel was not ineffective; Baltazar’s illegal conduct disqualified him from stand-your-ground and no reasonable probability of a different outcome existed given the evidence
Whether the district court abused its discretion by excluding two surveillance videos of the victim’s prior violent conduct	The videos were relevant to show the victim’s violent character and support Baltazar’s fear and self-defense claim	Videos were inadmissible as specific instances because Baltazar did not know of them; admitting them would be unfairly prejudicial	No abuse of discretion; under State v. Williams specific-conduct evidence is inadmissible when the defendant lacked prior knowledge

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test: deficiency and prejudice)
State v. Williams, 929 N.W.2d 621 (Iowa 2019) (defendant asserting self‑defense cannot prove victim’s violent character by specific conduct unknown to defendant)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (ineffective-assistance claims based on failure to preserve jury-instruction error require showing Strickland deficiency and prejudice)
State v. Ondayog, 722 N.W.2d 778 (Iowa 2006) (ineffective-assistance claims reviewed de novo under Strickland)
State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (discusses retreat/alternative-course-of-action as disqualifying for justification)
State v. Ambrose, 861 N.W.2d 550 (Iowa 2015) (prejudice requires reasonable probability the result would have been different)