State of Iowa v. Richard Anthony Rolon, 15-0893

Rolon was convicted at trial of first-degree burglary and second-offense domestic abuse assault.
Rolon appeals asserting ineffective assistance for not objecting to prior-bad-acts evidence and prosecutorial misconduct, and argues insufficient evidence for burglary bodily-injury element.
The district court admitted prior-violence evidence to prove specific intent for burglary; trial included a rebuttal closing by the prosecutor."
Three eyewitnesses testified to Rolon entering the home, breaking a window, and causing injuries to Cassandra and others.
Rolon testified he did not intend to hurt anyone; the court submitted both charges to the jury and denied motions for arrest of judgment and new trial.
The Iowa Court of Appeals affirms, finding no ineffective assistance and sufficient evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to object to 5.404(b) evidence	Rolon—prior-acts evidence improper and prejudicial	State—evidence relevant to intent; objections were approached	No prejudice; admission not prejudicial given defense theory and other evidence
Ineffective assistance for prosecutorial misconduct in rebuttal	Prosecutor urged conviction to prevent future assaults	Comment isolated; strong evidence of guilt	Not prejudicial; did not deny a fair trial
Sufficiency of evidence for burglary-intent to injure	Insufficient proof Rolon intended to injure	Evidence showed recklessness and intent to enter for assault	Substantial evidence supports conviction, including window breach and injuries
Court's breadth of evidence review	N/A	N/A	Court properly viewed evidence in light most favorable to State

State v. Straw, 709 N.W.2d 128 (Iowa 2006) (ineffective-assistance standards and prejudice required)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (two-prong test for ineffective assistance)
State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (prior-acts admissible to prove intent; probative value vs prejudice)
State v. Rodriquez, 636 N.W.2d 234 (Iowa 2001) (relevance of prior-acts balancing prejudice)
State v. Keopasaeuth, 645 N.W.2d 637 (Iowa 2002) (standard for sufficiency review and reasonable inferences)
State v. Graves, 668 N.W.2d 860 (Iowa 2003) (prejudice and fair-trial considerations in prosecutorial-misconduct claims)
State v. Greene, 592 N.W.2d 24 (Iowa 1999) (analysis of whether misconduct denied fair trial)
State v. Hanes, 790 N.W.2d 545 (Iowa 2010) (instructional curative effect of court on misconduct)