Christopher Allen Puccio, Applicant-Appellant v. State of Iowa, 15-1850

Puccio pleaded guilty to forgery (Iowa Code §715A.2) and delivery of a controlled substance (Iowa Code §124.401) after admitting during plea colloquy to using his brother’s ID to claim casino winnings and selling ecstasy to an undercover officer.
Initial plea called for suspended consecutive sentences while Puccio awaited placement in a residential treatment facility; he absconded before sentencing, was arrested, and the parties renegotiated, resulting in concurrent terms of incarceration.
Puccio filed a postconviction-relief (PCR) application alleging ineffective assistance of plea counsel on three grounds: (1) the pleas were not knowing and voluntary due to mental-health issues and lack of medication; (2) the pleas lacked a factual basis; and (3) counsel failed to provide him the trial information/minutes of testimony.
At the plea colloquy Puccio affirmed he understood the proceedings, the charges, and consequences; counsel testified he communicated effectively with Puccio and followed office practice in providing documents.
The district court denied PCR; the court of appeals reviewed ineffective-assistance claims de novo and affirmed, finding Puccio failed to overcome the strong record showing his pleas were knowing, voluntary, and supported by a factual basis, and that counsel did not perform deficiently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pleas were knowing and voluntary given mental-health diagnoses and missed medication	Puccio: mental conditions and lack of meds impaired his ability to understand charges and consequences, rendering pleas involuntary	State: plea colloquy and counsel’s testimony show Puccio understood proceedings; no evidence meds impaired capacity	Court: Pleas were knowing and voluntary; Puccio failed to rebut record; no ineffective assistance for not filing motion in arrest of judgment
Whether there was a factual basis for the guilty pleas	Puccio: colloquy was brief and did not sufficiently develop elements, so factual basis lacking	State: Puccio admitted elements and minutes/witnesses would support conviction; record suffices	Court: Record and admissions provide a factual basis; counsel not ineffective for failing to challenge it
Whether counsel failed to provide trial information/minutes as required	Puccio: counsel did not give him the information before plea as required by rule	State: counsel testified it was standard practice to provide the information and there was no reason he wouldn’t have done so	Court: District court credited counsel’s testimony; no relief warranted
Whether counsel was ineffective generally for not pursuing meritless challenges	Puccio: counsel should have pursued post-plea motions	State: such motions would have been meritless	Court: Counsel not deficient for failing to pursue meritless claims; no prejudice shown

Strickland v. Washington, 466 U.S. 668 (ineffective-assistance-of-counsel standard: deficient performance and prejudice)
Liddell v. State, 672 N.W.2d 805 (Iowa) (de novo review of ineffective-assistance claims)
State v. Straw, 709 N.W.2d 128 (Iowa) (in guilty-plea context, defendant must show he would have gone to trial but for counsel’s errors)
Castro v. State, 795 N.W.2d 789 (Iowa) (colloquy statements showing understanding defeat collateral attack)
Arnold v. State, 540 N.W.2d 243 (Iowa) (applicant bears special burden when record contradicts assertions about plea validity)
State v. Schminkey, 597 N.W.2d 785 (Iowa) (requirement that guilty plea be supported by a factual basis)
State v. Keene, 630 N.W.2d 579 (Iowa) (consider entire record—defendant statements, prosecutor, minutes—when assessing factual basis)
State v. Brubaker, 805 N.W.2d 164 (Iowa) (counsel not incompetent for failing to pursue meritless issues)
State v. Velez, 829 N.W.2d 572 (Iowa) (record need only demonstrate facts that support the offense)