State of Iowa v. Craig Anthony Finney
2013 Iowa Sup. LEXIS 82
Iowa2013Background
- Finney was charged with attempted murder of Patty Harker and other offenses; minutes alleged the shooting incident and sequence of events.
- Finney pled guilty to attempted murder in exchange for dismissal of other charges; plea colloquy touched on his admission ('I shot Patty').
- The district court sentenced Finney to 25 years and ordered restitution; Finney appealed alleging ineffective assistance for lack of a factual basis in the plea.
- The Iowa Court of Appeals vacated the conviction and remanded, citing Philo and requiring explicit articulation of the factual basis on the record.
- The Supreme Court granted review and held that the record as a whole supports a factual basis for the plea and affirmed the district court judgment.
- The court emphasized two strands of analysis: Sixth Amendment ineffectiveness (objective factual basis) and due process voluntariness (subjective understanding).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lack of explicit on-record factual basis invalidate plea | Finney: no factual basis shown in plea colloquy | Finney: counsel ineffective for not ensuring factual basis | No relief; record supports factual basis |
| Whether minutes can supply the factual basis for the plea | Finney: minutes cannot substitute for on-record basis | State: minutes may supplement the record to establish factual basis | Minutes provide adequate factual basis for attempted murder |
| Whether Iowa rule 2.8(2)(b) requires on-record factual basis disclosure | Finney: rule requires explicit on-record basis; absence is reversible error | State: entire record may be considered; not reversible error if substantial | Rule 2.8(2)(b) requires on-record basis, but complete record supports conviction |
Key Cases Cited
- State v. Sisco, 169 N.W.2d 542 (Iowa 1969) (ABA standards require factual basis before judgment)
- State v. Fluhr, 287 N.W.2d 857 (Iowa 1980) (colloquy vs. substantive compliance for voluntariness and factual basis)
- Henderson v. Morgan, 426 U.S. 637 (U.S. 1976) (due process limits on guilty-plea voluntariness when elements unclear)
- McCarthy v. United States, 394 U.S. 459 (U.S. 1969) (Rule 11 factual basis and voluntariness; need for record inquiry)
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (record must show voluntary and intelligent waiver of rights)
- State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (entire record may establish factual basis for plea)
- State v. Rodriguez, 804 N.W.2d 844 (Iowa 2011) (look to minutes of testimony and record for factual basis)
- State v. Philo, 697 N.W.2d 481 (Iowa 2005) (absence of explicit on-record basis requires articulation of evidence)
- State v. Straw, 709 N.W.2d 128 (Iowa 2006) (substantial-compliance approach to plea-bargaining errors)