State of Iowa v. Martin Guerrero-Adame
State of Iowa v. Martin Guerrero-Adame
Opinion
A twelve-year-old girl told a forensic interviewer that her grandmother's husband touched her breasts and vagina. The State charged Martin Guerrero-Adame with third-degree sexual abuse, in violation of Iowa Code section 709.4(1)(b)(2) (2016). Following a bench trial, the district court found him guilty as charged.
On appeal, Guerrero-Adame contends his trial attorney was ineffective "in presenting" an expert who, in the eyes of the district court, did nothing to advance his cause. To prevail he must show (1) deficient performance and (2) prejudice.
See
Strickland v. Washington
,
The defense called a psychiatrist to the stand. He spoke in generalities about protocols for forensic interviews. He then agreed with the defense attorney that the forensic interviewer who spoke to the child should have "gone into more detail." When asked why, he responded, "The more information one has, the better-you know, the more it substantiates, you know, the issue." Defense counsel pressed for specifics. The psychiatrist answered, "I think, just, you know, to get a better understanding of how that particular action played out as much as one could."
Defense counsel next asked the psychiatrist whether he had any "medical opinions." He responded, "I didn't give an opinion, mainly because I couldn't give an opinion. I didn't evaluate all parties. I thought that there were gaps in the information, and frankly, I couldn't come up with an opinion."
The district court found the psychiatrist's testimony unhelpful. After noting that he failed to "interview anyone in connection with this case" and gave "no opinion as to the case," the court characterized the expert's testimony as "a lot of circular gobbledygook that did not shed any light on this case." The court expressed uncertainty as to "why the doctor was called."
We agree the psychiatrist added little to the defense presentation. But he also did not "bolster[ ] the State's case," as Guerrero-Adame asserts. His testimony and report aided neither side.
See
State v. Clay
,
AFFIRMED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.