Chavez Martez-Nash, Applicant-Appellant v. State of Iowa, 16-0017

Background

In 2012 Chavez Martez‑Nash, age 17 at the time, was charged with first‑degree murder and criminal gang participation; he pleaded guilty to four lesser felonies as part of a plea agreement.
Before pleading, defense counsel discussed the plea and estimated Martez‑Nash might be in prison about two years and nine months but gave no guarantees.
The district court accepted the plea and immediately sentenced Martez‑Nash to consecutive maximum terms on each count, totaling 35 years; there were no statutory mandatory minimums for parole eligibility.
Martez‑Nash did not appeal the plea or sentence; he filed a postconviction‑relief (PCR) application after learning he was unlikely to be released after the estimated 2 years, 9 months.
In the PCR he alleged (1) ineffective assistance of counsel for allegedly misleading him about time to release and for not challenging sentence constitutionality, and (2) that his sentence was unconstitutional under recent juvenile‑sentencing caselaw.
The district court denied relief; on appeal the Court of Appeals affirmed, reviewing ineffective‑assistance and the constitutional challenge de novo.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance — counsel’s alleged misinformation about release date	Martez‑Nash says counsel told him he would likely be released about 2 years, 9 months, inducing his guilty plea	State says counsel gave only an estimate and no guarantee; defendant cannot show prejudice required to undo plea	Affirmed — Martez‑Nash failed to prove prejudice (no reasonable probability he would have gone to trial); relief unavailable to reset parole date
Ineffective assistance — failure to challenge sentence constitutionality	Martez‑Nash contends counsel should have challenged the sentence as unconstitutional for a juvenile	State says sentences lacked mandatory minimums implicated by juvenile‑sentencing cases, so challenge would fail	Affirmed — no prejudice shown; court need not decide breach of duty
Legality/constitutionality of sentence under juvenile‑sentencing precedents (Lyle)	Martez‑Nash argues ineligibility for probation on two counts functionally created a mandatory minimum, triggering Lyle protections and need for individualized age‑based consideration	State argues Lyle applies to statutory mandatory minimums; here sentences had no mandatory minimum terms and Lyle does not apply	Affirmed — sentences are not unconstitutional under Lyle; no entitlement to individualized juvenile hearing absent mandatory minimums
Requested remedy (reset discharge date / resentencing)	Martez‑Nash sought vacatur or reset of discharge to 2 years, 9 months or remand for mitigation hearing	State argues sentencing court cannot order parole dates or invade legislative/parole board authority; remedy unavailable	Affirmed — court cannot order specific parole timing; requested remedy unavailable

Key Cases Cited

Strickland v. Washington, 466 U.S. 688 (1984) (two‑part test for ineffective assistance: duty and prejudice)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (held mandatory minimums for youthful offenders unconstitutional under Iowa Constitution; limited to statutory mandatory minimum schemes)
State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (sentences imposed without statutory authorization are illegal and void; legislative sentencing authority)
Remmers v. Iowa Dist. Ct., 259 N.W.2d 779 (Iowa 1977) (sentencing court limited to selecting maximum term; parole board sets actual time served)
Castro v. State, 795 N.W.2d 789 (Iowa 2011) (standard of review for PCR denials; ineffective‑assistance claims reviewed de novo)
State v. Draper, 457 N.W.2d 600 (Iowa 1990) (sentencing court may not depart from legislatively authorized sentence)