State of Iowa v. Bernard Anthony Smith, 924 N.W.2d 846

Bernard Anthony Smith was convicted by a jury of second-degree burglary; during jury deliberations he (through counsel) stipulated to predicate prior convictions for a habitual-offender enhancement.
The district court accepted Smith’s oral affirmation that the stipulation was voluntary but did not engage in a full colloquy or obtain a written, signed stipulation.
The court later sentenced Smith as a habitual offender to a term not to exceed 15 years, with other monetary orders; Smith appealed.
Smith did not file a motion in arrest of judgment to preserve any challenge to the habitual-offender stipulation after sentencing.
The State Supreme Court considered whether the court complied with the colloquy and error-preservation requirements articulated in State v. Harrington for habitual-offender stipulations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Smith preserved challenge to habitual-offender stipulation under Harrington	State: Harrington requires a motion in arrest of judgment to preserve errors; Smith did not file one	Smith: Court failed to inform him adequately of need and consequences of such a motion, so failure to file should be excused	Court: Error-preservation rule applies but is excused here because the court did not substantially comply with its duty to inform Smith of the necessity and consequences
Whether the district court complied with Harrington’s colloquy requirements for a voluntary, intelligent stipulation	State: The court accepted a voluntary affirmation and that sufficed	Smith: Colloquy lacked required advisals (nature of charge, factual basis, max punishment including mandatory minimum parole ineligibility, trial rights, and link to motion in arrest)	Court: Colloquy was inadequate; cannot conclude admission was knowing and voluntary; reversal of habitual-offender judgment and sentence and remand required

State v. Harrington, 893 N.W.2d 36 (Iowa 2017) (establishes colloquy and error-preservation requirements for habitual-offender stipulations)
State v. Brewster, 907 N.W.2d 489 (Iowa 2018) (applies Harrington to other repeat-offender enhancement proceedings)
State v. Kukowski, 704 N.W.2d 687 (Iowa 2005) (discusses similarity between prior-offense stipulations and guilty pleas for sentencing enhancements)
State v. Worley, 297 N.W.2d 368 (Iowa 1980) (recognizes exception to plea-preservation rule when court fails to advise defendant of motion-in-arrest requirement)
State v. Straw, 709 N.W.2d 128 (Iowa 2006) (applies substantial-compliance standard to advisals about motion in arrest of judgment)
State v. Fisher, 877 N.W.2d 676 (Iowa 2016) (addresses role of written plea documents in evaluating substantial compliance)