State of Iowa v. Cristina Kaye Briones, 17-0798

Defendant Cristina Briones pled guilty to driving while barred after being stopped while operating a vehicle on January 20, 2017.
Department of Transportation records showed Briones’s license was barred effective November 28, 2016, through November 27, 2018.
Briones later asserted trial counsel was ineffective for allowing the guilty plea because it prevented challenging her driving status on appeal.
The district court accepted the plea and convicted Briones; she appealed claiming ineffective assistance of counsel.
The Court of Appeals reviewed the claim on the merits because the record was adequate to decide the ineffective-assistance claim on direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for allowing a guilty plea without a factual basis	State: The minutes and DOT notice establish Briones was driving and her license was barred, providing a factual basis	Briones: Counsel was ineffective because pleading guilty foreclosed a challenge to her driving status and she was unaware of her barred status	Court: Counsel was not ineffective; record provided a factual basis and lack of knowledge of barred status is irrelevant to the elements
Whether knowledge or intent is an element of driving while barred	State: Knowledge/intent is not required for the offense	Briones: Argued unawareness of barred status undermines plea basis	Court: Held knowledge/intent not required; only operation and barred status are elements

State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (standard of review for ineffective-assistance claims)
State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (two-prong ineffective-assistance test)
State v. Straw, 709 N.W.2d 128 (Iowa 2006) (failure of either prong defeats claim)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (preserving vs deciding ineffective-assistance claims on direct appeal)
State v. Schminkey, 597 N.W.2d 785 (Iowa 1999) (prejudice presumed where guilty plea lacks factual basis)