State of Iowa v. Trevor Lee Martin, 16-2069

On August 28, 2016, Trevor Martin walked a Fort Dodge neighborhood carrying a loaded Ruger .22 semi-automatic rifle, threatened bystanders, and briefly let a child handle the gun before it was taken from him and police arrested him.
Martin was charged with and convicted by a jury of being a felon in possession of a firearm under Iowa Code § 724.26(1).
At trial the court instructed the jury on the elements of the offense and defined “firearm” and “possession,” but did not define the term “knowingly.”
Defense counsel did not request the Iowa uniform jury instruction defining “knowledge.”
On appeal Martin argued counsel was ineffective for failing to request a definitional instruction on “knowingly,” denying him due process and a fair trial.
The district court sentenced Martin to an indeterminate five-year prison term; the Court of Appeals reviewed the ineffective-assistance claim de novo and resolved it on the existing record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defense counsel was ineffective for failing to request a jury instruction defining “knowingly”	State: Counsel’s omission did not fall below professional norms because “knowingly” is ordinary language and need not be defined	Martin: Counsel breached a duty by not requesting the uniform instruction on “knowledge,” leaving jurors free to convict without a conscious awareness the item was a firearm	Court: No ineffective assistance — no duty to request definition; “knowingly” is a word of ordinary usage and did not require a special instruction

State v. Hoffer, 383 N.W.2d 543 (Iowa 1986) (holding “knowledge” is a word of common usage and need not be defined as a legal term)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
State v. Ambrose, 861 N.W.2d 550 (Iowa 2015) (standard of review for ineffective-assistance claims)
State v. Virgil, 895 N.W.2d 873 (Iowa 2017) (performance and prejudice standards for counsel review)
State v. Russell, 897 N.W.2d 717 (Iowa 2017) (both prongs required for finding ineffective assistance)
United States v. Smith, 635 F.2d 716 (8th Cir. 1980) ("knowledge" is within ordinary juror understanding)