State of Iowa v. Andre Letroy Antwan Harrington, 2017 Iowa Sup. LEXIS 33

Background

Harrington was convicted by a jury of second‑degree robbery; the State sought a habitual‑offender enhancement based on two prior felonies, which would increase exposure to a 15‑year sentence with a 70% mandatory minimum.
At sentencing the court asked whether Harrington would stipulate to the prior convictions or want a jury trial on them; Harrington acknowledged the convictions but said he wanted the jury to decide the habitual‑offender question. The court accepted his admission and did not reconvene a jury.
The district court informed Harrington that his admission meant no trial would occur, but did not advise him about certain constitutional and statutory rights (e.g., that the priors had to have been obtained with counsel or valid waiver, the specific mandatory minimum, full trial rights, or that defects must be raised by motion in arrest of judgment).
Harrington appealed, arguing the colloquy accepting his admission was constitutionally and statutorily deficient and that the court should have allowed withdrawal of the admission; the court of appeals affirmed, finding failure to preserve error and no abuse of discretion.
The Iowa Supreme Court granted further review, held that a motion in arrest of judgment is the proper preservation vehicle for deficiencies in habitual‑offender admissions (but applied that requirement prospectively and excused Harrington’s failure), and found the colloquy deficient such that Harrington did not knowingly and voluntarily admit the priors.
The Supreme Court vacated the court of appeals decision, reversed the district court as to the enhancement, and remanded for further proceedings or a trial on habitual‑offender status; the conviction for the underlying robbery was left intact.

Issues

Issue	Harrington's Argument	State's Argument	Held
Whether errors in the habitual‑offender colloquy must be preserved by a motion in arrest of judgment	Deficient colloquy claims need not be preserved in that manner (or, at least, his failure should be excused)	A motion in arrest of judgment (and contemporaneous objection) is required to preserve challenges to the colloquy	A motion in arrest of judgment is the correct vehicle and preservation requirement applies prospectively; Harrington’s failure excused here
Whether an admission to prior convictions is equivalent to a guilty plea for voluntariness/information requirements	Admission must be voluntary/intelligent; Harrington argues the court failed to inform him of key rights and consequences so admission was not knowing	The admission is narrower than a guilty plea; rule 2.19(9) does not require all guilty‑plea advisals and the record showed awareness	Admission is analogous to a guilty plea for purposes of voluntariness; the court must conduct a colloquy covering specified matters; Harrington’s admission was not knowingly and voluntarily made
Scope of required colloquy when accepting admissions to priors	Court failed to inform him of need for counsel/waiver at priors, specific mandatory minimum, full trial rights, or motion in arrest of judgment requirement	Rule 2.19(9) does not mandate all Rule 2.8(2) advisals; many disclosures are unnecessary or redundant	Court must: explain nature of habitual‑offender charge; confirm priors were obtained with counsel or valid waiver (or address burden‑shifting); state maximum and mandatory minimum penalties; advise of trial rights applicable to the enhancement phase; state that admission waives trial on priors and that defects must be raised by motion in arrest of judgment
Whether the district court abused discretion by refusing to let Harrington withdraw his admission	He argued his later request for a jury should be treated as a withdrawal request	Court and State argued no timely withdrawal request was made and no abuse occurred	No abuse of discretion found on the record because Harrington did not timely request withdrawal; court did not reach prejudice analysis

Key Cases Cited

State v. Kukowski, 704 N.W.2d 687 (Iowa 2005) (admission to priors must be voluntary and intelligent; court must inquire before accepting)
State v. Brady, 442 N.W.2d 57 (Iowa 1989) (habitual‑offender admissions analogous to guilty pleas for advisory purposes)
State v. Oetken, 613 N.W.2d 679 (Iowa 2000) (court must inform defendant of ramifications of habitual‑offender adjudication)
State v. Loye, 670 N.W.2d 141 (Iowa 2003) (guilty plea rules embody constitutional requirements for plea advisals)
Almendarez‑Torres v. United States, 523 U.S. 224 (1998) (recidivism as traditional basis for sentence enhancement)
State v. Cameron, 167 N.W.2d 689 (Iowa 1969) (burden‑shifting framework when prior conviction records are silent about counsel)
Parke v. Raley, 506 U.S. 20 (1992) (procedural due process standards for proof allocation in collateral‑fact challenges)
State v. Finney, 834 N.W.2d 46 (Iowa 2013) (prejudice requirement in abuse‑of‑discretion review of withdrawal of admissions)