State of Iowa, Appellee v. Zyriah Henry Floyd Schlitter, Appellant

Summary

The court held that trial counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting one alternative theory of child endangerment. Because the jury returned a general verdict that may have rested on that unsupported theory, the court ordered a new trial limited to the supported alternatives. The court also held that Schlitter was not in Miranda custody during his police-station interview and therefore affirmed admission of his statements. Justice Appel, joined by Justices Wiggins and Hecht, would have found the interrogation custodial and suppressed statements obtained after Schlitter repeatedly asked officers to stop; Justice Wiggins separately addressed special interrogatories for alternative theories.