cumulative error in Iowa

2025Three of the forgery counts concerned Hasselmann’s use of fraudulent checks, while the fourth was for his use of a fraudulent driver’s license. 1 Because we resolve all Hasselmann’s claims on the duty prong, we need not consider his argument that “trial counsel’s cumulative errors prejudiced him.” See McPeek v. State, No. 22-1870, 2024 WL 2042115 , at *3 (Iowa Ct. App. May 8, 2024) (“We only engage in a cumulative-error inquiry when we ‘analyze[] the prejudice prong of Strickland without considering trial counsel’s failure to perform an essential duty.’” (alteration in original) (quoting State

2024We only engage in a cumulative-error inquiry when we “analyze[] the prejudice prong of Strickland without considering trial counsel’s failure to perform an essential duty.” Id. at 501– 02. 8 Here, defense counsel did not breach any duty when pursuing the trial strategy and avoiding certain evidence about McPeek and the victim’s relationship.

2025“To prevail on a claim of ineffective assistance of counsel, the applicant must demonstrate both ineffective assistance and prejudice.” Ledezma v. State, 626 N.W.2d 134, 142 (Iowa 2001); see Strickland v. Washington, 466 U.S. 668, 687 (1984).

2022Any breach that may have occurred with that claim does not undermine our confidence in the outcome, see Strickland, 466 U.S. at 694 , so we reject the cumulative-error claim, see Pantaleon, 2021 WL 592928 , at *4; accord Clay, 824 N.W.2d at 501–02.

2025“To prevail on a claim of ineffective assistance of counsel, the applicant must demonstrate both ineffective assistance and prejudice.” Ledezma v. State, 626 N.W.2d 134, 142 (Iowa 2001); see Strickland v. Washington, 466 U.S. 668, 687 (1984).

2025One of the amendments also removed the theft-by-taking alternative after the supreme court’s decision in State v. Nall, 894 N.W.2d 514, 524 (Iowa 2017), which held that to “‘[take] possession or control’” under section 714.1(1), “a person must acquire property without the consent or authority of another.” Hasselmann claims that defense counsel “was ineffective in failing to inform [him] of the amendments to the trial information and object to them.” The postconviction court rejected this claim, as do we.