State v. Liggins, 19-0945

CourtUnited States State Supreme Court of Iowa
Writing for the CourtAPPEL, JUSTICE
PartiesSTATE OF IOWA, Appellee, v. SANLEY LIGGINS, Appellant.
Docket Number19-0945
Decision Date30 June 2022

STATE OF IOWA, Appellee,
v.

SANLEY LIGGINS, Appellant.

No. 19-0945

Supreme Court of Iowa

June 30, 2022


Submitted September 16, 2021

Appeal from the Iowa District Court for Scott County, Marlita A. Greve, Judge.

Defendant appeals his conviction for first-degree murder after his fourth retrial. Defendant seeks a new trial or dismissal based on juror misconduct, evidentiary errors, and due process violations. AFFIRMED.

Martha J. Lucey, State Appellate Defender, Melinda J. Nye (argued), Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, Richard Bennett (argued), Special Counsel, for appellee.

Appel, J., delivered the opinion of the court, in which all justices joined.

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APPEL, JUSTICE

In this case, Stanley Liggins raises a number of challenges to his conviction of first-degree murder arising from events in 1990 after his fourth trial almost thirty years after the crime. Liggins asserts that his conviction cannot stand as a result of (1) juror misconduct, (2) the admission of transcript testimony of a deceased witness without a full opportunity for cross-examination, (3) the admission of unreliable testimony from a witness who provided an inconsistent and changing version of events, (4) the admission of unreliable testimony from a jailhouse informant, (5) the admission of an eyewitness who was intoxicated when first identifying Liggins from a photo array and whose subsequent trial identification was tainted by one-person-identification procedures, (6) the erroneous exclusion of hearsay statements from a witness who recalled comments of the victim about abuse at home years prior to her death, and (7) a violation of due process because his trial occurred more than thirty years after the events as a result of delays arising in part from the granting of a motion for postconviction relief and a subsequently hung jury.

For the reasons expressed below, we affirm the conviction.

I. Factual and Procedural Background.

A. Procedural Background.

Stanley Liggins was first charged with murder, willful injury, first-degree sexual abuse, and first-degree kidnapping in connection with the death of J.L. on September 17, 1990. On appeal, we concluded that there was jurisdiction in Iowa to support the criminal prosecution

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for murder but no other alleged offenses, that the State offered sufficient evidence to support a murder charge, that Liggins was not in custody when questioned and voluntarily consented to a search of his apartment, and that testimony related to a jailhouse confession was sufficiently corroborated to be admissible. State v. Liggins, 524 N.W.2d 181, 184-88 (Iowa 1994). However, we also found that evidence that Liggins had sold cocaine to the victim's mother and her husband was irrelevant, improperly admitted into evidence, and inherently prejudicial. Id. at 188-89. Because of the taint of the improperly admitted evidence, Liggins's convictions were reversed and the case remanded for a new trial on the murder charge. Id. at 189.

Upon retrial, Liggins was convicted of first-degree murder. Liggins again appealed. State v. Liggins, 557 N.W.2d 263 (Iowa 1996). On his second appeal, we held that there was evidence to support jurisdiction in Iowa, that jury instructions related to felony murder and participating in a public offense were proper, that the admission of prior trial and deposition testimony of a mentally incompetent witness did not violate Liggins's Sixth Amendment rights under the Federal Constitution, and that there was sufficient evidence to support the verdict. Id. at 266-70.

Liggins then filed an action for postconviction relief in the district court. Liggins v. State, No. 99-1188, 2000 WL 1827164, at *1 (Iowa Ct. App. Dec. 13, 2000). He alleged that the State suppressed evidence and knowingly allowed a witness to present false testimony, that newly discovered evidence required a

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new trial, and that direct appeal counsel was ineffective for failing to challenge the change of venue from Davenport to Dubuque. Id.

The district court appointed a special master to review the files of the prosecution and the defense to determine what information was not in the defense files. Id. The special master determined that the State had not disclosed seventy-seven police reports. Id. Liggins focused his attack on four reports of witnesses that were withheld from the defense. Id. The district court, however, found that the undisclosed reports were not material on the issue of guilt. Id. The district court also rejected Liggins's claim that the State knowingly put on false testimony from several witnesses. Id. at *6. The district court further rejected claims that newly discovered evidence justified a new trial, id. at *7-10, and that Liggins's counsel was ineffective for failing to object to a change of venue to Dubuque County, which Liggins claimed was a "hotbed for racial hatred," id. at *7-9.

The court of appeals affirmed the district court on all claims. Id. at *4-5, 10. The court of appeals emphasized that there is no reasonable probability that the result would have been different if the suppressed evidence had been produced. Id. at *10. At the time of the 2000 appeal, the sole issue was the failure of the State to produce witness statements with respect to four witnesses. Id. at *1-5 (relating to Sarah Bea, Daryl Sheese, Shawn Saunders, and Michael Armstrong).

In 2007, Liggins launched a second action for postconviction relief. Liggins v. State, No. 12-0399, 2013 WL 5963013, at *1 (Iowa Ct. App. Nov. 6, 2013).

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Among other things, Liggins alleged that the State withheld information that W.H., a witness who placed a vehicle owned by Liggins in the vicinity of the body, was a paid informant. Id. At the hearing before the district court, Liggins established that W.H. was a paid informant who participated in as many as eighty drug buys for the Davenport police. Id. The district court concluded that the State had improperly withheld the information but ultimately decided that the evidence was not material to the outcome. Id. at *1-2.

The court of appeals reversed. Id. at *8. It found that when considered in context, the cumulative impact of the withholding of exculpatory information from the three witnesses in the first action for postconviction relief and the withholding of information about the informant activity of a key prosecution witness in the second postconviction proceeding required a new trial. Id. at *4- 8.

Liggins's third trial commenced on August 30, 2018. The jury failed to reach a verdict after three days of deliberation, and the district court declared a mistrial.

Liggins's fourth trial began on March 12, 2019. The jury returned a guilty verdict. The district court denied Liggins's posttrial motion for a new trial. This appeal followed.

B. Factual Overview of Evidence at Fourth Trial.

The State's evidence at trial revealed that on September 17, 1990, nine-year-old J.L. returned to her home in Rock Island after shopping with her mother, Sheri, and stepfather, Joseph Glenn. At that time, a number of adults were coming and going from the

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house, including Stanley Liggins. Shortly after arrival at the Glenn home, J.L. left on a bicycle to play with friends. Liggins left the home shortly after J.L.'s departure.

Liggins owned a red or maroon four-door Peugeot with his girlfriend, Brenda Adams. The mother of a friend of J.L.'s testified that on the afternoon of September 17, she saw Liggins stop his Peugeot while J.L. was on her bike and talk with her outside the witness's home. Another neighborhood woman testified she saw a man in a red or maroon four-door Peugeot beckon J.L. to the car and talk to her that afternoon.

J.L. later returned home. Liggins returned to the Glenn home as well. Liggins gave J.L. a dollar and asked her to go to the nearby Mac's Liquor store to purchase gum for him. She left on foot. After J.L. left the home, Liggins also left. The owner of the liquor store testified that between 6:15 and 6:30 p.m., J.L. entered the store and bought a pack of gum "for a friend."

A State's witness, Antonio Holmes, testified that he had gone to the same convenience store to buy beer after 6 p.m. and saw an African-American male standing outside. He asked the man, "How's it going," and got the response, "Okay." Inside the store, Holmes saw J.L. getting bubble gum and some change. She then left the store. After Holmes bought some beer, he exited the store. The man he had seen earlier was gone.

Four days after September 17, Holmes contacted the police after he learned J.L. had been killed. At the police station, he was interviewed and shown a photo lineup. He picked Liggins's photo as the person he had seen outside

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Mac's Liquor store. The interviewing police officer noted that Holmes had been drinking and was under the influence of alcohol. The next day, however, Holmes contacted the police and told them he was drunk the previous night and was not sure of his identification of the suspect. He returned to the station on the 23rd and was shown only one photo-that of Liggins-and asked if that was the man he had seen outside of Mac's Liquor store on September 17. Holmes stated that he could not be sure. The police followed with, "You're not sure. It looks a lot like him[?]" Holmes answered, "Yeah." Two years later, at his deposition, Holmes positively identified Liggins as the man he saw outside the liquor store. When asked how he could be so sure after two years' passage of time, he said he just knew. Later at trial, he responded that it was because he was seeing him in the flesh and not as a photo.

At about 7:00 p.m., the Glenns became concerned that J.L. had not returned home. They began to search for her. Liggins called the Glenn home at about 7:38 p.m. to enquire whether J.L. had returned home and was informed that she had not. Liggins then arrived at the...

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