State of Iowa v. Charles Edward Ross, 941 N.W.2d 341

In the early morning of Sept. 24, 2018, Charles Ross and a codefendant cut a padlock and steel cable securing a riding lawn mower at a Mills Fleet Farm, loaded the mower into a rental truck, and fled; an employee observed them and police later recovered the mower and bolt cutters.
Ross was charged with second-degree theft (felony), possession of a tool with intent to remove a "theft detection device" (serious misdemeanor, Iowa Code §714.7B(3)), and possession of methamphetamine (misdemeanor).
Ross entered a plea agreement, pleading guilty to the theft and the §714.7B(3) misdemeanor; the court accepted his written plea and imposed a seven-year aggregate sentence including a 365-day term for the §714.7B(3) conviction.
On appeal Ross argued trial counsel was ineffective for permitting a guilty plea to §714.7B(3) because the padlock+steel cable did not constitute a "theft detection device," so no factual basis supported the plea.
The Iowa Supreme Court agreed the statute was ambiguous and concluded the padlock+steel cable was a theft-prevention device, not a theft-detection device, and therefore vacated Ross’s §714.7B(3) conviction and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a padlock secured to a steel cable wrapped around merchandise qualifies as a "theft detection device" under Iowa Code §714.7B(4) such that possession of tools to remove it is criminal under §714.7B(3)	The State: the statute’s broad definition covers any "device" attached to merchandise; padlock+cable is an "other device" attached to merchandise and thus a theft-detection device	Ross: "theft detection device" requires a detection/alert function; a padlock+cable only prevents theft and does not detect or alert, so it is not covered	Court held the padlock+steel cable is a theft-prevention device, not a theft-detection device; statute construed to require a detection function; Ross’s guilty plea to §714.7B(3) lacked factual basis and was vacated; counsel ineffective

State v. Nall, 894 N.W.2d 514 (Iowa 2017) (counsel errs by allowing plea without factual basis; prejudice inherent)
State v. Coleman, 907 N.W.2d 124 (Iowa 2018) (statutory interpretation principles; plain language controls when unambiguous)
Auen v. Alcoholic Beverages Div., 679 N.W.2d 588 (Iowa 2004) (courts must not extend or change statute meaning)
State v. Schminkey, 597 N.W.2d 785 (Iowa 1999) (remedies when record lacks factual basis for guilty plea)
State v. Gines, 844 N.W.2d 437 (Iowa 2014) (prejudice is inherent when plea entered without factual basis)
State v. Brown, 930 N.W.2d 840 (Iowa 2019) (ineffective-assistance claims and standards)