State of Iowa v. Riley Augustus Mallett, 16-0565

On Feb. 10, 2015 Greenwood Pharmacy was robbed by two masked men; one wielded a handgun and demanded prescription drugs. Victim Pilkington identified Mallett as the gunman; distinctive black puffy pants with white stars were left near where Mallett was found hiding.
Police tracked Mallett to a treehouse; matching pants were found nearby. Cody Plummer was arrested and implicated Mallett; K’Von Henderson, Dayton Nelson, and Myles Anderson were later identified as participants. Nelson testified at trial that Mallett and Plummer executed the robbery and others assisted as drivers/handlers.
Mallett was tried with co-defendants; a mistrial occurred in November 2015 and a retrial in February 2016 resulted in convictions for first-degree robbery for Mallett, Plummer, and Henderson.
On appeal Mallett raised preserved and ineffective-assistance claims and a constitutional challenge to his mandatory sentence as cruel and unusual for a youthful offender.
The court affirmed the conviction in large part but remanded for the district court to reconsider Mallett’s motion for a new trial under the proper weight-of-the-evidence standard.

Issue	State's Argument	Mallett's Argument	Held
Trial court’s standard on motion for new trial	Denial based on prior rulings and motion for acquittal	Trial court applied sufficiency rather than weight-of-the-evidence standard	Remanded: trial court must apply weight-of-the-evidence standard
Legality of mandatory sentence (cruel & unusual for youth)	Mandatory first-degree robbery sentence valid under existing law	Mandatory minimum is cruel and unusual for a ~20‑year‑old (relies on Sweet/Lyle)	Rejected here; claim considered but did not warrant relief on record
Ineffective assistance — speedy-trial waivers	Waivers were valid and knowingly signed by Mallett	Counsel ineffective for causing Mallett to waive speedy-trial rights	Denied: written waivers and acknowledgments enforceable; no counsel fault shown
Ineffective assistance — jury instructions (joint-criminal-conduct)	Instruction was appropriate and not misleading	Counsel ineffective for not objecting to joint-criminal-conduct instruction	Denied: instruction did not misstate culpability; any error would be superfluous/no prejudice
Ineffective assistance — severance & prosecutorial conduct	No basis for severance; evidence of association admissible to show acquaintance	Counsel ineffective for failing to sever; prosecutor engaged in misconduct by not using lineup/corroboration	Denied: co‑defendant allegations were typical conflicting defenses; no prosecutorial duty to use lineup; credibility matters for jury

State v. Ellis, 578 N.W.2d 657 (Iowa 1998) (weight-of-the-evidence standard for new-trial motions)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (youthful-offender analysis and Eighth Amendment review)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (challenge to mandatory sentences for youthful offenders)
State v. Jefferson, 574 N.W.2d 268 (Iowa 1997) (joint criminal conduct instruction may include reasonably foreseeable unplanned acts)
State v. Smith, 739 N.W.2d 289 (Iowa 2007) (no error to give joint-criminal-conduct instruction when facts leave no other plausible theory)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (two-prong ineffective-assistance standard: breach and prejudice)