State of Iowa v. Barbara Kay Svoboda, 16-1018

Barbara Svoboda was charged with an aggravated-misdemeanor forgery and faced multiple related felony charges in two other cases; she entered a global plea agreement resolving all cases.
At the plea hearing the prosecutor described the forgery, the court recessed so Svoboda could read the information and minutes, and she confirmed she understood the charge and wanted to plead guilty.
The court explained rights waived by a guilty plea (including counsel-assisted confrontation) and advised Svoboda she could challenge the plea by filing a motion in arrest of judgment within specified deadlines.
Svoboda’s plea counsel did not file a motion in arrest of judgment; the court later sentenced Svoboda to a suspended term with probation, consecutive to other sentences.
Svoboda appealed claiming the plea was defective under Iowa R. Crim. P. 2.8(2)(b) (court failed to ensure she understood the nature of the charge and her right to counsel at trial).
The court held Svoboda was barred from a direct appeal because she was adequately warned about filing a motion in arrest of judgment, so she pursued an ineffective-assistance-of-counsel claim for failing to file that motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Svoboda can directly appeal plea adequacy	State: Court substantially complied with rule 2.8(2)(d); written + oral advisals were adequate	Svoboda: Plea colloquy failed to ensure she understood the forgery elements and right to counsel at trial	Court: Substantial compliance; direct appeal barred without motion in arrest of judgment
Whether counsel had duty to file motion in arrest of judgment	State: Counsel had no duty because colloquy was adequate and issues would be meritless	Svoboda: Counsel should have filed because plea colloquy was defective under rule 2.8(2)(b)	Court: No duty—colloquy and prosecutor’s explanation made charge and trial-rights clear
Whether counsel’s omission was ineffective assistance (performance)	State: Counsel’s failure to file was not a breach of essential duty	Svoboda: Failure to file shows counsel’s ineffectiveness	Court: No breach—no duty to pursue meritless issue
Whether Svoboda was prejudiced by counsel’s omission	State: Svoboda did not show she would have gone to trial but for counsel’s omission	Svoboda: Implied prejudice from defective plea process	Court: No prejudice; Svoboda did not contend she would have refused plea and appellate record shows she did not want to withdraw pleas

Strickland v. Washington, 466 U.S. 668 (ineffective assistance two-prong test)
Hill v. Lockhart, 474 U.S. 52 (prejudice inquiry for guilty-plea challenges)
State v. Straw, 709 N.W.2d 128 (Iowa: motion in arrest of judgment & counsel-based alternative)
State v. Fisher, 877 N.W.2d 676 (Iowa: substantial compliance with Rule 2.8(2)(d))
State v. Philo, 697 N.W.2d 481 (Iowa: defendant must understand elements and nature of charge)