Ronnie Sanders, Applicant-Appellant v. State of Iowa
15-0711
| Iowa Ct. App. | Oct 12, 2016Background
- Ronnie Sanders was charged with a B felony and went to trial after rejecting a State plea offer to plead to a C felony.
- Sanders filed an application for postconviction relief (PCR) claiming ineffective assistance of trial counsel for failing to explain the plea offer, which he says he would have accepted.
- At the PCR hearing, Sanders testified he would have accepted the second plea offer if counsel had explained the agreement and the sentencing consequences.
- Trial counsel testified he had discussed the plea offer with Sanders, recorded Sanders’ on-the-record rejection, and felt Sanders was unwilling to accept the deal.
- The PCR court credited trial counsel’s testimony over Sanders’ and dismissed the PCR.
- On appeal, the Iowa Court of Appeals reviewed the constitutional claim de novo and affirmed the dismissal, finding no breach of duty by counsel and no prejudice shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel provided ineffective assistance by failing to explain the plea offer | Sanders: counsel did not adequately explain the plea or sentencing consequences, so he would have accepted the C-felony plea | State/Trial counsel: counsel discussed the offer, explained pros/cons, and Sanders on the record rejected it | Court: No breach of duty; counsel credibly communicated the offer and client refused |
| Whether Sanders proved prejudice under plea-vacatur standard (would have accepted plea) | Sanders: would have accepted plea given sentencing differences | State: Sanders’ testimony is self-serving; record shows rejection and counsel’s explanation | Court: Sanders failed to show reasonable probability he would have accepted the plea |
| Whether the plea would likely have been accepted by prosecution/court if Sanders had accepted | Sanders: implied it would have been accepted | State: no evidence prosecution or court would have refused | Court: Not reached as Sanders failed other prongs; no reasonable probability shown |
| Standard of review for constitutional claim on PCR appeal | Sanders: de novo review applies to constitutional claims | State: agrees de novo review applies | Court: applied de novo review and affirmed PCR dismissal |
Key Cases Cited
- Reilly v. Iowa Dist. Ct., 783 N.W.2d 490 (Iowa 2010) (constitutional issues in PCR reviewed de novo)
- Lamasters v. State, 821 N.W.2d 856 (Iowa 2012) (two-part Strickland framework for ineffective-assistance claims)
- Dempsey v. State, 860 N.W.2d 860 (Iowa 2015) (to show prejudice for a rejected plea, must show outcome of plea process would likely differ)
- Missouri v. Frye, 132 S. Ct. 1399 (2012) (defense counsel has duty to communicate formal plea offers)
- Lafler v. Cooper, 132 S. Ct. 1376 (2012) (prejudice from ineffective assistance during plea bargaining assessed by whether plea outcome would have been different)