State of Iowa v. Quintorey Kemp, 16-0946

Kemp was found guilty by a jury of assault while participating in the felony of going armed with intent after Sherman Wise testified Kemp pointed and fired a handgun at him.
Incident: Wise found Kemp in his daughter’s bedroom, a physical altercation occurred, Kemp ran, Wise saw Kemp point a handgun and fire multiple shots at him outside the house.
Kemp’s mother and father testified for the defense; on cross-examination each acknowledged bullets had been found in Kemp’s room a year earlier. Defense counsel did not object to those questions.
The jury was instructed it must find Kemp committed an assault and, at the time, was participating in going armed with intent, which requires specific intent to use a firearm against Wise.
Kemp appealed, arguing trial counsel was ineffective for failing to object to testimony about prior bullets, which he contended improperly suggested propensity and undermined his lack-of-intent defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not objecting to testimony that bullets were found in Kemp’s room a year earlier	State: evidence of bullets was admissible or not outcome-determinative given eyewitness and other evidence	Kemp: counsel breached duty by not objecting; prior-bullet evidence unfairly suggested propensity and prejudiced specific-intent defense	Court: No prejudice — even if counsel erred, overwhelming eyewitness and other evidence make a different outcome unlikely; conviction affirmed

Strickland v. Washington, 466 U.S. 668 (ineffective-assistance standard requiring breach and prejudice)
State v. Harris, 891 N.W.2d 182 (preservation and review of ineffective-assistance claims)
State v. Reynolds, 746 N.W.2d 837 (prejudice definition under Strickland)
State v. Thorndike, 860 N.W.2d 316 (courts may proceed directly to prejudice prong)
State v. Matlock, 715 N.W.2d 1 (other-bad-acts evidence cannot be used to show propensity for specific-intent crimes)