Anna Sothman v. State of Iowa, 967 N.W.2d 512

In June 2016 Sothman left her 13-month-old daughter unattended in a bathtub for roughly 25–35 minutes; the child drowned and later died.
Sothman pleaded guilty to child endangerment resulting in death (class B, indeterminate up to 50 years); court accepted plea and advised parole timing is up to the parole board.
Plea counsel told Sothman he relied on an LSA fiscal note showing an average time served of 4.6 years and that she would be immediately eligible for parole; he did not research beyond the fiscal note.
At sentencing the judge conducted a short in‑chambers, on‑the‑record colloquy with Sothman under oath; counsel did not obtain or record a waiver of the public‑hearing right or object.
Years later Sothman filed a postconviction relief (PCR) claim alleging ineffective assistance based on inaccurate parole prognosis and counsel’s failure to object to the in‑chambers proceeding; the district court and court of appeals denied relief.
The Iowa Supreme Court affirmed: counsel did not breach an essential duty in parole advice and, although counsel should have objected to the in‑chambers colloquy, Sothman failed to show prejudice under applicable precedent including Weaver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea counsel's parole advice was constitutionally deficient	Counsel misinformed Sothman by emphasizing a 4.6‑year average and suggesting likely early release; had she known the true timeline she would not have pleaded guilty	Counsel reasonably relied on the LSA fiscal note, told client there were no guarantees, and did not misstate parole law; any prediction was nonbinding	No breach of essential duty; advice was a reasonable reliance on LSA data and did not establish prejudice because Sothman failed to show she would have insisted on trial
Whether counsel's failure to object to an in‑chambers, on‑the‑record colloquy violated the right to a public proceeding and amounted to ineffective assistance	Counsel should have insisted on open‑court colloquy or obtained an on‑the‑record waiver; lack of public proceeding tainted voluntariness	Even if counsel erred, PCR requires proof of prejudice for unpreserved public‑trial errors; the in‑chambers colloquy was not shown to be fundamentally unfair or outcome‑determinative	Counsel breached duty by not objecting or securing a waiver, but Sothman failed to prove Strickland prejudice; Weaver requires prejudice for unpreserved public‑trial claims in PCR, so no relief granted

Hill v. Lockhart, 474 U.S. 52 (1985) (applies Strickland prejudice standard to guilty‑plea challenges)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance of counsel)
Weaver v. Massachusetts, 137 S. Ct. 1899 (2017) (postconviction, unpreserved public‑trial violations require proof of prejudice)
Waller v. Georgia, 467 U.S. 39 (1984) (public‑trial right and standards for courtroom closure)
Meier v. State, 337 N.W.2d 204 (Iowa 1983) (counsel must not misinform defendant about collateral consequences)
Diaz v. State, 896 N.W.2d 723 (Iowa 2017) (counsel must advise on truly clear collateral consequences; prejudice inquiry framed by rational‑choice analysis)
Doss v. State, 961 N.W.2d 701 (Iowa 2021) (PCR review of ineffective‑assistance claims and requirement to show prejudice)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (presumption of competent performance; avoid hindsight in assessing counsel)