IA: No IAC for not challenging evidence obtained in another state where state law was more defense favorable; can’t show outcome would be different

Defendant was arrested in Nebraska, and Iowa authorities sought his DNA there to connect him to an Iowa crime. Nebraska’s standard for obtaining DNA is less demanding. He can’t show on post-conviction that defense counsel was ineffective for not challenging the Nebraska standard in Iowa because he can’t show any probability of a different outcome. Armstrong v. State, 2018 Iowa App. LEXIS 875 (Sep. 26, 2018). It doesn’t say that the conflict of laws determination wouldn’t matter, just that he can’t show prejudice.

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