Mark Angelo Castro v. State of Iowa
2011 Iowa Sup. LEXIS 17
| Iowa | 2011Background
- Castro pled guilty to five counts of third-degree sexual abuse after being charged with five counts of second-degree sexual abuse.
- Crimes involved repeated sexual contact with a seven-year-old girl over about four months; Castro lived with the child’s grandmother, where abuse occurred.
- Castro made numerous statements to police after being advised of Miranda rights and signing a written waiver.
- Plea hearing included colloquy where the court found the plea voluntary and intelligent; Castro claimed medications did not impair understanding.
- Castro was sentenced to five consecutive ten-year terms in prison.
- Castro sought postconviction relief alleging (i) pre-plea ineffective assistance of counsel, (ii) ineffective assistance related to mental health/medication, and (iii) medication changes before the plea affecting voluntariness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pre-plea ineffective assistance is intrinsic to the plea and survives the guilty plea | Castro | State | Remanded for evaluation; improper summary adjudication in part |
| Whether the pre-plea alleged ineffective assistance was properly tied to voluntariness of the plea | Castro | State | Castro properly showed intrinsic relation; district court erred in granting summary judgment |
| Whether evidence about medication changes and mental state creates a genuine issue of material fact regarding voluntariness | Castro | State | Summary judgment improper; need evidentiary hearing to resolve medical causation |
Key Cases Cited
- Wise v. State, 708 N.W.2d 66 (Iowa 2006) (intrinsic irregularities and plea voluntariness considerations)
- Carroll v. State, 767 N.W.2d 638 (Iowa 2009) (intrinsic irregularities and survival of pre-plea ineffectiveness)
- Speed v. State, 616 N.W.2d 158 (Iowa 2000) (pre-plea counsel failures generally do not survive a guilty plea)
- Nitcher v. State, 720 N.W.2d 547 (Iowa 2006) (constitutional claims in postconviction relief)
- Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (de novo review of postconviction relief for constitutional issues)
- Ridinger v. State, 341 N.W.2d 734 (Iowa 1983) (summary judgment standards in postconviction relief)
- Parish v. Jumpking, Inc., 719 N.W.2d 540 (Iowa 2006) (requirement of genuine issues of material fact in response to summary judgment)
- Ranes v. Adams Labs., Inc., 778 N.W.2d 677 (Iowa 2010) (expert medical testimony required for complex causation issues)
- DeVoss v. State, 648 N.W.2d 56 (Iowa 2002) (plea-related grounds on appeal)
- Wallace v. Des Moines Indep. Cmty. Sch. Dist. Bd. of Dirs., 754 N.W.2d 854 (Iowa 2008) (summary judgment considerations in related contexts)