Thomas S. Millam v. State of Iowa

Summary

The Iowa Supreme Court held that Thomas Millam’s trial counsel provided ineffective assistance by failing to offer evidence that the child complainant had previously made false claims of sexual abuse. Because the evidence was central to the complainant’s credibility and the State’s case depended primarily on her testimony, the court found prejudice, vacated the court of appeals’ decision, affirmed the district court, and remanded for a new trial.

Holdings

1. Trial counsel breached an essential duty by failing to offer evidence that J.S. had previously made and later recanted similar claims of sexual abuse. Although Iowa law was unsettled at the time, counsel was required to research and assess whether the issue was worth raising rather than assume the evidence was barred by the rape-shield law.
2. Millam was prejudiced because there was a reasonable probability that evidence of J.S.'s prior false claims would have undermined her credibility and changed the outcome of the trial.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to investigate and offer evidence that the victim had previously made and recanted similar claims of sexual abuse.
2. Whether Millam was prejudiced by counsel's failure to present the prior-false-claims evidence.

Disposition

reversed_and_remanded