State of Iowa v. Trenton John Atterberg, 15-1672

Atterberg violently assaulted Jorgenson in the McDonald’s drive-through, causing injuries, which was captured on CCTV.
Frequent prior friendship between Atterberg and Jorgenson had soured; the incident occurred at about 12:50 a.m. in Keokuk, Iowa.
Atterberg was charged with first-degree burglary and possession of marijuana; a plea offer to assault causing bodily injury was extended but not accepted within time.
The State dismissed the marijuana charge after Atterberg rejected the plea, and the case proceeded to a jury trial.
Defense presented a theory that the vehicle was not an occupied structure or that there was no entry, and that burglary elements were not proven.
Atterberg was convicted by the jury and later argued ineffective assistance of counsel and cumulative error; the district court denied the new trial motion, and the conviction was affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Pretrial ineffective assistance—plea discussions	Atterberg claims counsel failed to adequately explain the plea and time to decide.	State contends defense counsel explained the plea and Atterberg chose to reject it.	No prejudice shown; Atterberg did not prove the decision was the result of ineffective assistance.
Ineffective assistance at trial—defense strategy	Counsel did not contest burglary elements and mishandled cross-examination.	Evidence of guilt was overwhelming; any errors did not prejudice the result.	No prejudice; overwhelming evidence supported guilt regardless of counsel’s handling.
Jury-selection recording—ineffective assistance claim	Waiver of reporting during jury impaneling was preserved but recording should have occurred.	No specific errors alleged about jury selection; waiver cannot support ineffective assistance.	No basis shown for ineffective assistance from waiver of recording.
Cumulative error	Cumulative errors denied fair trial.	No reversible errors when weighed cumulatively.	No cumulative prejudice; trial did not deny a fair trial; conviction affirmed.

State v. Cromer, 765 N.W.2d 1 (Iowa 2009) (prejudice requires proof that but-for errors the outcome would differ)
State v. Parker, 747 N.W.2d 196 (Iowa 2008) (overwhelming evidence can negate prejudice from counsel errors)
State v. Hildebrant, 405 N.W.2d 839 (Iowa 1987) (prefer prejudice-first approach to ineffective assistance)
Dunbar v. State, 515 N.W.2d 12 (Iowa 1994) (claim must specify how counsel was inadequate and how outcomes would differ)
State v. Droste, 232 N.W.2d 483 (Iowa 1975) (cumulative error analysis for fair trial)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (look to cumulative prejudice in Strickland analysis)
Ennenga v. State, 812 N.W.2d 696 (Iowa 2012) (standard for ineffective assistance review)