Duane Maynord Huffer v. State of Iowa

── Duane Maynord Huffer v. State of Iowa ── Court: Court of Appeals of Iowa Date: April 15, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 24-1631 Filed April 15, 2026 _______________ Duane Maynord Huffer, Applicant–Appellant, v. State of Iowa, Respondent–Appellee. _______________ Appeal from the Iowa District Court for Story County, The Honorable Melissa Anderson-Seeber, Judge. _______________ AFFIRMED _______________ Jamie Hunter of Dickey, Campbell & Sahag Law Firm, PLC, Des Moines, attorney for appellant. Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney General, attorneys for appellee. _______________ Considered without oral argument by Chicchelly, P.J., and Buller and Langholz, JJ. Opinion by Langholz, J. 1 LANGHOLZ, Judge. After pleading guilty to first-degree harassment, Duane Huffer filed a timely postconviction-relief (“PCR”) application challenging his conviction. Among other claims, he alleged many instances of prosecutorial misconduct and ineffective assistance of his counsel. Following a bench trial, the district court found that Huffer failed to show that he was prejudiced by any of the alleged instances of prosecutorial misconduct or that his defense counsel breached any essential duty. So the court denied relief. Huffer now appeals. On our review, we agree with the State that Iowa Code section 822.8 (2018) bars Huffer from raising his prosecutorial-misconduct claims in this PCR action because he failed to raise them during the criminal proceedings or in his direct appeal challenging the district court’s revocation of his deferred judgment. And the State asserted the procedural bar to Huffer’s claims in its answer to his PCR application. So we affirm the district court’s denial of relief on this alternative ground and decline to reach the merits of Huffer’s prosecutorial-misconduct claims. As for his ineffective-assistance-of-counsel claims, we find that Huffer has not adequately argued or established constitutional prejudice in the guilty-plea context. So these claims too must fail. We thus affirm the district court’s denial of Huffer’s PCR application. I. Background Facts and Proceedings In early 2018, Huffer’s then-wife reported to an Ames police officer that Huffer threatened to kill her and later put his hands around her neck while she was sleeping. The officer filed a criminal complaint alleging Huffer committed domestic-abuse assault impeding the flow of air or blood—an aggravated misdemeanor. See Iowa Code § 708.2A(2)(d). And the district 2 court entered a criminal no-contact order naming the assault victim as the protected party. The day after Huffer’s arrest, the Story County Attorney requested that a special prosecutor be appointed due to “a conflict of interest with the Story County Attorney’s Office.”1 Granting that request, the court appointed an assistant Polk County Attorney as the special prosecutor in Huffer’s case. After the special prosecutor “reviewed the full police report,” the State moved to amend the charges to one count of domestic-abuse assault—a simple misdemeanor—and one count of harassment in the first degree—an aggravated misdemeanor. See Iowa Code §§ 708.2A(2)(a), 708.7(1)(b), 708.7(2)(a)(1). The court granted the motion, and the State filed an amended complaint and trial information charging Huffer with those offenses. Huffer reached an agreement with the State to plead guilty to the first- degree harassment count. In exchange for his guilty plea