State of Iowa v. Clyde Arrington, 16-0584

Defendant Clyde Arrington pled guilty to failure to comply with the sex-offender registry as a second or subsequent offender and was sentenced to up to five years’ imprisonment.
At plea hearing Arrington admitted he failed to register after being informed of requirements when he registered in June 2014 and acknowledged prior convictions requiring registration.
Arrington did not file a motion in arrest of judgment after pleading guilty and later challenged his conviction on appeal, alleging ineffective assistance of counsel for permitting a plea without factual basis.
Sentencing was scheduled, continued for cooperation negotiations, then reset; Arrington’s counsel withdrew and new counsel was appointed shortly before sentencing, and the court denied a motion to continue.
The district court cited Arrington’s significant criminal history, prior supervision failures, and the PSI recommendation in imposing incarceration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for permitting a guilty plea lacking factual basis	State: plea transcript and registration evidence supply factual basis; counsel not ineffective	Arrington: plea lacks factual basis on knowledge of registration duty; counsel breached essential duty	Court held there was a factual basis (admissions + evidence of June 2014 notice); no ineffective assistance
Whether denial of motion to continue sentencing was an abuse of discretion	State: case pending long time; counsel could prepare by reviewing PSI and meeting client in ~a week	Arrington: new counsel needed more time, potentially to file motion in arrest of judgment	Court held denial not an abuse of discretion; motion in arrest deadline already lapsed
Whether sentence to incarceration lacked sufficient reasons	State: sentencing grounded in criminal history, supervision failures, PSI recommendation	Arrington: court failed to state adequate reasons for imprisonment	Court held reasons given were sufficient; sentence affirmed

State v. Straw, 709 N.W.2d 128 (Iowa 2006) (failure to file motion in arrest bars direct appeal absent ineffective-assistance claim)
Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (counsel breaches essential duty by allowing plea without factual basis; prejudice presumed)
State v. Artzer, 609 N.W.2d 526 (Iowa 2000) (standards on timely sentencing and denial of continuance reviewed for abuse of discretion)
State v. Johnson, 513 N.W.2d 717 (Iowa 1994) (sentencing decisions carry strong presumption of correctness)
State v. Thompson, 856 N.W.2d 915 (Iowa 2014) (requirements for stating reasons on the record to review sentencing discretion)