Darryl Tyson, Applicant-Appellant v. State of Iowa, 15-1863

Darryl Tyson pled guilty to first-degree burglary, second-degree robbery, third-degree sexual abuse, and second-degree theft; district court imposed consecutive prison terms totaling up to 50 years.
Tyson later filed an application for postconviction relief (PCR) claiming trial counsel was ineffective for failing to advise him that consecutive sentences could total 50 years and for inadequate investigation.
The district court held an evidentiary hearing and denied relief; Tyson appealed asserting (1) his plea was unknowing because he did not understand consecutive sentencing and (2) ineffective assistance by PCR counsel in presenting trial-counsel failures.
At the plea hearing the prosecutor stated the individual terms and expressly said the sentences were to run consecutively for a total not to exceed 50 years; the court confirmed Tyson understood the ranges of punishment.
Trial counsel testified the plea provided benefits: removal or reduction of mandatory minimum exposure and avoided the risk of multiple consecutive mandatory-minimum sentences if convicted at trial.

Issue	Tyson's Argument	State's Argument	Held
Whether Tyson's guilty plea was unknowing because he did not understand consecutive sentencing	Tyson says he wasn’t warned or asked if he understood "consecutive", so plea was constitutionally deficient	The plea record, including prosecutor’s explicit statement and court’s recitation of punishment ranges, put Tyson on notice of the 50-year consecutive exposure; counsel’s performance was not deficient	Court held plea was knowing; counsel did not breach duty and Tyson showed no prejudice
Whether trial counsel was ineffective for failing to challenge the plea as unknowing	Tyson argues counsel should have objected or moved in arrest of judgment	State points to the plea colloquy and prosecutor’s statement; counsel negotiatd benefits reducing mandatory minimum exposure	Court held no deficient performance and no prejudice under Strickland
Whether PCR counsel was ineffective for failing to develop record on trial-counsel omissions (alibi, DNA, camera surveillance)	Tyson contends PCR counsel failed to investigate witnesses, DNA challenges, and surveillance that could have supported trial-counsel ineffectiveness	State notes PCR record elicited testimony on these topics and that further development risked bolstering State evidence; family testimony would undercut alibi; DNA comparisons and samples were in the record; no request was made to check cameras	Court held PCR counsel’s choices were reasonable; no breach of duty

Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard: deficient performance and prejudice)
State v. White, 587 N.W.2d 240 (Iowa 1998) (vacating plea where defendant received no information about consecutive sentencing)
Castro v. State, 795 N.W.2d 789 (Iowa 2011) (prejudice component for plea voluntariness tied to whether defendant would have gone to trial)
State v. Brubaker, 805 N.W.2d 164 (Iowa 2011) (deference to counsel’s reasonable choices; avoid hindsight second-guessing)