State of Iowa v. Robert Lynn Vaughan, 859 N.W.2d 492

On October 20, 2011, two deliberately set fires occurred at Robert Vaughan’s residence and detached garage; investigators found two separate points of origin and remnants of an improvised incendiary device with gasoline.
Vaughan moved/sold personal property and had vehicles/dogs relocated shortly before the fires; insurance claim for house and ~$25,000 personal property followed and was denied after investigation.
Vaughan was charged with first‑degree arson; the public defender W. Jon Henson was initially appointed.
Henson also represented George Cline, who later told police Vaughan had solicited him to start a fire; upon learning Cline would be a State witness, Henson moved to withdraw and Gordon Liles was appointed on August 22, about 3½ months before trial.
At trial (Dec. 17–19), the State presented circumstantial evidence (distinct origins, accelerant, motive, moved property) and called Cline; Liles vigorously cross‑examined Cline.
Vaughan challenged (1) sufficiency of the evidence and (2) that Henson’s earlier conflict required a new trial; the court of appeals ordered a new trial but the supreme court vacated that decision and affirmed the conviction.

Issue	Plaintiff's Argument (Vaughan)	Defendant's Argument (State)	Held
Sufficiency of the evidence for 1st‑degree arson	Evidence did not directly implicate Vaughan; conviction rests on circumstantial proof	Circumstantial evidence (two distinct fires, accelerant, placement of belongings, motive, moved items, presence of others) supports conviction	Affirmed: circumstantial evidence sufficient to convict beyond a reasonable doubt
Conflict of interest from Henson’s representation of Cline and Vaughan	Henson’s dual representation (May–Aug 2012) created an actual conflict requiring presumptive prejudice and new trial	Henson withdrew and conflict‑free counsel (Liles) was appointed ~3½ months before trial; no showing the prior conflict adversely affected performance	Affirmed: replacement with conflict‑free counsel well before trial cured any potential conflict; defendant failed to show an adverse effect on counsel’s performance

Holloway v. Arkansas, 435 U.S. 475 (1978) (automatic reversal when trial court forces multiple representation over timely objection)
Cuyler v. Sullivan, 446 U.S. 335 (1980) (when no objection, defendant must show an actual conflict that adversely affected counsel)
Wood v. Georgia, 450 U.S. 261 (1981) (remand to determine whether an actual conflict existed where court raised issue sua sponte)
Mickens v. Taylor, 535 U.S. 162 (2002) (clarified that absence of inquiry does not automatically require reversal; defendant must show conflict adversely affected counsel)
State v. Watson, 620 N.W.2d 233 (Iowa 2000) (prior Iowa decision requiring reversal where court knew/should have known of conflict and failed to inquire)
State v. Smitherman, 733 N.W.2d 341 (Iowa 2007) (where court inquired or relief equivalent provided, defendant must show adverse effect to prevail)
Nix v. Williams, 467 U.S. 431 (1984) (fruit‑of‑the‑poisonous‑tree exceptions; evidence obtained in violation may be admissible if inevitably discovered or from independent source)
State v. Veverka, 271 N.W.2d 744 (Iowa 1978) (arson convictions can rest on circumstantial evidence)