State of Iowa v. Adam D. Dodson, 17-0044

Adam Dodson pleaded guilty to domestic abuse assault in violation of Iowa Code § 708.2A(2)(c).
The written plea agreement included multiple check-marked provisions, including a firearms prohibition (no possession, shipment, transport, or receipt of firearms, offensive weapons, or ammunition).
Dodson signed the plea agreement; the district court accepted the plea, sentenced him consistent with the State’s recommendation, and entered a no-contact order prohibiting firearm possession.
On appeal, Dodson argued his trial counsel was ineffective for failing to file a motion in arrest of judgment challenging the guilty plea.
Dodson asserted he was unaware his plea would trigger the firearm prohibition and questioned who had marked the firearm provision in the written agreement.
The appellate court found the record adequate to decide the claim and noted the written plea fully disclosed the firearm prohibition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to file a motion in arrest of judgment	State: counsel’s performance was adequate; plea and consequences were disclosed	Dodson: counsel failed to challenge plea validity; he was unaware plea would bar firearm possession	Court held counsel was not ineffective; plea agreement disclosed the firearm prohibition and record was adequate to reject the claim

State v. Clay, 824 N.W.2d 488 (Iowa 2012) (standard of review for ineffective-assistance claims)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (two-part Strickland-style test for ineffective assistance)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (prejudice requirement and addressing claims on direct appeal when the record is adequate)
State v. Straw, 709 N.W.2d 128 (Iowa 2006) (permitting ineffective-assistance claims on direct appeal when the record suffices)