David Scott Daughenbaugh v. State of Iowa, 2011 Iowa Sup. LEXIS 85

Daughenbaugh, a pharmacist, was arrested for theft after an inventory search uncovered numerous prescription drugs he intended to destroy; he pled guilty to three felonies and one aggravated misdemeanor, in exchange for a deferred judgment and dismissal of one misdemeanor.
The district court accepted the guilty pleas, granted a deferred judgment, placed Daughenbaugh on two years of supervised probation, and imposed conditions including therapy and random drug testing.
A DHS letter later notified him that he was excluded from healthcare programs due to felony convictions, rendering him virtually unemployable as a pharmacist.
Daughenbaugh filed a postconviction relief petition alleging ineffective assistance of counsel and challenging whether his plea and deferred judgment amounted to a “conviction” under Iowa law for postconviction relief.
The district court allowed the postconviction claim to proceed, rejected Galloway-based reasoning, and adopted a Schilling framework, ultimately ruling there was a factual basis for his pleas but that counsel was not ineffective.
The Iowa Supreme Court affirmed, holding that, for purposes of postconviction relief, a deferred judgment is a strict legal adjudication and thus a deferred-judgment guilty plea does not constitute a “conviction.”

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a deferred judgment renders a conviction for postconviction relief	Daughenbaugh contends deferred judgment is not a conviction under §822.2	State argues there is a factual basis for guilt and that a deferred judgment can be a conviction	Deferred judgment is not a conviction under §822.2; relief denied

State v. Hanna, 179 N.W.2d 503 (Iowa 1970) (conviction meaning varies by context; general sense used in some statutes)
State v. Farmer, 234 N.W.2d 89 (Iowa 1975) (adjudication of guilt may be implied from sentence; deferred judgment not an adjudication of guilt)
State v. Kluesner, 389 N.W.2d 370 (Iowa 1986) (purpose of statute governs whether ‘conviction’ is narrow or broad in meaning)
State v. Schilling, 646 N.W.2d 70 (Iowa 2002) (punishment vs. protective statute; broad vs. narrow meaning of ‘conviction’)
State v. Stessman, 460 N.W.2d 461 (Iowa 1990) (deferred judgment is not a final judgment for direct appeal; informs direct vs postconviction context)
Caldwell v. Dretke, 429 F.3d 521 (5th Cir. 2005) (whether deferred adjudication is a ‘judgment’ for AEDPA purposes)
Burton v. Stewart, 549 U.S. 147 (2007) (final judgment means sentence; state of the law after Caldwell)
State v. Tong, 805 N.W.2d 599 (Iowa 2011) (statutory context; pleading date of entry of judgment governs")
State v. Nail, 743 N.W.2d 535 (Iowa 2007) (statutory context; how ‘convicted’ is read in pleading)
State v. Farmer, 234 N.W.2d 89 (Iowa 1975) (reiterated for adjudication timing in probation revocation)