Curtis Johnson-Jeffers III, Applicant-Appellant v. State of Iowa, 16-0680

Curtis Johnson-Jeffers III pleaded guilty to stalking in violation of a protective order, escape, second-offense domestic abuse causing bodily injury, first-degree harassment, and related probation/no-contact violations; the district court accepted the pleas and suspended sentence per plea agreement.
After his suspension was revoked and a ten-year maximum term was imposed, Johnson-Jeffers filed a postconviction relief (PCR) application claiming his stalking plea was not knowing, intelligent, and voluntary and that trial counsel was ineffective for allowing the plea without explaining elements and without a factual basis.
At plea proceedings and in the minutes of testimony, the victim described a course of conduct: two in-person violent encounters (including repeated blows to the head and death threats) and threatening messages and social-media contacts despite a no-contact order.
Johnson-Jeffers asserted he would not have pled guilty if he had understood the stalking elements; he did not move in arrest of judgment after the plea was accepted and before sentence suspension was revoked.
The district court denied PCR; Johnson-Jeffers appealed, and the appellate court reviewed ineffective-assistance claims de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea was knowing because court/counsel failed to inform defendant of stalking elements	Johnson-Jeffers: counsel didn’t explain elements so plea was uninformed and involuntary	State: even if elements weren’t explained, Johnson-Jeffers cannot show prejudice from counsel’s omission	Court held no prejudice shown; claim fails
Whether counsel was ineffective for not explaining elements	Johnson-Jeffers: counsel breached duty by allowing plea without element understanding	State: defendant received favorable plea and benefits; self-serving assertion insufficient to show he would have gone to trial	Court held prejudice not established; ineffective-assistance claim denied
Whether plea lacked factual basis for stalking conviction	Johnson-Jeffers: alleged lack of understanding implies no factual basis	State: minutes, defendant’s admissions, and victim’s recounting provided clear factual basis	Court held record contains sufficient factual basis; counsel not ineffective
Whether prejudice should be presumed because counsel failed to stop plea hearing	Johnson-Jeffers: argues plea would not have been entered if counsel intervened	State: no authority supports presuming prejudice; courts refuse per se prejudice rules	Court refused to presume prejudice; claim rejected

Castro v. State, 795 N.W.2d 789 (Iowa 2011) (standard of review for PCR and ineffective-assistance framework)
State v. Liddell, 672 N.W.2d 805 (Iowa 2003) (failure to prove either prong of ineffective-assistance test is fatal)
State v. Straw, 709 N.W.2d 128 (Iowa 2006) (defendant must show reasonable probability they would have gone to trial; court rejects per se prejudice rule)
State v. Velez, 829 N.W.2d 572 (Iowa 2013) (a factual basis is required for a guilty plea)
State v. Schminkey, 597 N.W.2d 785 (Iowa 1999) (facts and reasonable inferences may establish defendant's intent)
State v. Finney, 834 N.W.2d 46 (Iowa 2013) (minutes of testimony can provide sufficient evidence to infer requisite intent)
State v. Dudley, 766 N.W.2d 606 (Iowa 2009) (counsel need not raise meritless issues)