Joey Dupree Coates, Applicant-Appellant v. State of Iowa, 16-0324

Coates pled guilty to second-degree murder and first-degree robbery pursuant to a plea agreement in which the State would recommend concurrent sentences.
He was originally represented by one lead attorney (among two), later replaced by substitute counsel; Coates waived claims against the original counsel at the PCR hearing.
At the plea colloquy Coates affirmed the pleas were voluntary, said he was satisfied with substitute counsel, and admitted factual bases for both crimes.
Coates sought postconviction relief claiming substitute counsel coerced him into pleading guilty and that his PCR counsel performed ineffectively.
The PCR court found Coates knew how to complain or request new counsel, the plea avoided much harsher exposure (life without parole), and there was no evidence of coercion or ineffective assistance causing prejudice.
The appellate court reviewed ineffective-assistance claims de novo and affirmed denial of PCR relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substituted trial counsel coerced Coates into pleading guilty	Coates: substitute counsel pressured/coerced him to accept the plea	State: record shows voluntariness, Coates satisfied with counsel, and had opportunity to seek new counsel	Held: No coercion; plea was voluntary and corroborated by colloquy and PCR testimony
Whether substitute counsel provided ineffective assistance leading to an involuntary plea	Coates: counsel breached duties in plea preparation and advice	State: counsel explored defenses; plea avoided far worse sentence; no deficient performance shown to cause prejudice	Held: Ineffective-assistance claim fails for lack of prejudice and contradicted by record
Whether PCR counsel was ineffective in presenting Coates' claims	Coates: PCR counsel did not adequately present his case	State: errors at PCR not shown; Coates waived some claims and those proceeded were unsupported	Held: PCR counsel’s performance did not prejudice Coates; relief denied
Whether claims against original counsel remained for review	Coates: argued original counsel breached ethics re: client control of defense	State: Coates waived claims at PCR trial	Held: Claims against original counsel were waived and not addressed on appeal

DeVoss v. State, 648 N.W.2d 56 (Iowa 2002) (finding State waived an issue)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (standard of review for PCR and de novo review for constitutional claims)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (citing Strickland standard)
Castro v. State, 795 N.W.2d 789 (Iowa 2011) (need for case-by-case analysis whether counsel breached duty before plea and whether plea was unintelligent or involuntary)
State v. Carroll, 767 N.W.2d 638 (Iowa 2009) (discussing standards for plea-related claims)