Thomas Anthony Miller, Applicant-Appellant v. State of Iowa, 16-0442

Miller was convicted of second-degree murder after claiming at trial he intended to commit suicide and accidentally fatally stabbed the victim during a struggle; he was initially charged with first-degree murder.
At trial, the State moved in limine to exclude testimony from Sister Nadine Meyer about the Catholic Church’s formal position on suicide; the motion was sustained without prejudice to an offer of proof; no offer was made and Sister Meyer did not testify.
Miller argued his failure to disclose the suicide/accident account to police and family was because of his and his family’s Catholic aversion to suicide; he sought to call Sister Meyer to prove the Church’s teachings supported that explanation.
On postconviction review Miller claimed trial counsel was ineffective for not making an offer of proof to admit Sister Meyer’s testimony; the PCR action was tried on stipulation and included Sister Meyer’s deposition.
Sister Meyer’s deposition established only the Church’s general adverse view of suicide, that teachings varied by parish, and she had no knowledge of Miller’s personal beliefs or parish instruction; record showed Miller had prior suicide threats/attempts known to family.
The district court denied relief; the Court of Appeals affirmed, holding counsel was not ineffective because Meyer’s testimony was not sufficiently relevant and no prejudice was shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not making an offer of proof to admit Sister Meyer’s testimony	Miller: counsel should have offered Meyer’s testimony to explain why he did not tell police/family about the suicide/accident theory (religious aversion to suicide)	State: Meyer’s testimony would not show Miller’s or his family’s specific beliefs or parish instruction and thus was not relevant; no prejudice shown	Court: No ineffective assistance — Meyer’s testimony was not relevant to Miller’s credibility gaps and no prejudice shown
Whether Sister Meyer’s testimony was relevant to explain Miller’s inconsistent statements	Miller: Church doctrine would explain inconsistency	State: Church’s general position is insufficient to prove Miller’s or family’s beliefs or training; Miller had prior suicide threats/attempts	Court: Not relevant — testimony was general and would not have overcome prior inconsistent statements
Whether failure to preserve the in limine issue foreclosed review	Miller: raised postconviction ineffective-assistance claim	State: issue preserved for PCR	Court: Error preservation satisfied because raised and decided in PCR
Whether prejudice under Strickland/Ledezma was shown	Miller: but-for counsel’s failure, reasonable probability of different outcome	State: no reasonable probability because testimony would not help and counsel need not make meritless offers	Court: No prejudice; claim fails

Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (error is preserved when issue is raised before and ruled on by the court)
Lamasters v. State, 821 N.W.2d 856 (Iowa 2012) (standard of review for PCR denials involving constitutional issues)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (Strickland-type ineffective assistance framework and prejudice standard)
Taylor v. State, 352 N.W.2d 683 (Iowa 1984) (presumption counsel is competent)
Artzer, 609 N.W.2d 526 (Iowa 2000) (defendant entitled only to representation within normal range of competency)
Brubaker, 805 N.W.2d 164 (Iowa 2011) (counsel not ineffective for failing to make a meritless objection)