State of Iowa v. Ryan Lee Stockbauer, 17-0898

Early-morning single-vehicle crash into a tree; defendant Ryan Stockbauer found crawling from driver-side, truck had heavy front-end damage.
Officer observed signs of intoxication (smell of alcohol, unsteady balance, bloodshot/watery eye); HGN test showed 2/6 indicators; defendant refused preliminary breath test and later refused chemical testing at the hospital.
Nurse discovered a small baggie of methamphetamine concealed in defendant’s underwear at the hospital; State charged him with OWI and possession of a controlled substance.
At trial, prosecutor’s voir dire asked jurors about personal or family experience with controlled substances; several jurors described methamphetamine’s bad effects.
Prosecutor’s opening/closing referenced injured passengers and used 16 crash-scene photographs (some showing deployed airbags and blood-stained seats); closing emphasized neighborhood risk and nighttime crash.
Jury convicted on both counts; on appeal defendant argued trial counsel was ineffective for failing to object to alleged prosecutorial misconduct intended to inflame the jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not objecting to alleged prosecutorial misconduct (voir dire, opening/closing, photos)	State: record inadequate to resolve ineffective-assistance claims on direct appeal; preserve for PCR.	Stockbauer: counsel breached duty by failing to object to inflammatory voir dire, statements, and photographs, causing prejudice.	Court: Affirmed convictions; preserved ineffective-assistance claims for possible postconviction relief because the record is inadequate to evaluate counsel’s strategy on direct appeal.

State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (ineffective-assistance claims ordinarily reserved for postconviction proceedings so record can be developed)
State v. Schlitter, 881 N.W.2d 380 (Iowa 2016) (distinguishes prosecutorial misconduct from prosecutorial error; defines misconduct)
State v. Henderson, 908 N.W.2d 868 (Iowa 2018) (standard of review for ineffective-assistance claims)
Strickland v. Washington, 466 U.S. 668 (1984) (defendant must show counsel breached essential duty and prejudice)