State of Iowa v. Daquon Boldon, 954 N.W.2d 62

Background

Boldon pleaded guilty to possession of a firearm by a felon, interference with official acts while armed, and carrying weapons pursuant to a plea agreement: State would recommend concurrent sentences and was free to argue for incarceration; defendant could argue for any sentence; fines suspended.
Plea accepted March 25, 2019; sentencing was continued and ultimately occurred July 1, 2019—the effective date of the 2019 omnibus crime bill that limited appeals from guilty pleas and required ineffective-assistance claims be raised in postconviction relief.
At sentencing the prosecutor recommended concurrent terms (as agreed) but argued for incarceration and identified factors including Boldon’s juvenile adjudications; defense sought a deferred judgment based on youth and rehabilitation prospects.
The district court rejected deferred judgment, imposed consecutive sentences totaling up to 12 years, and cited Boldon’s extensive juvenile history and pattern of firearms/violent offenses.
On appeal Boldon argued (1) the prosecutor breached the plea agreement by effectively recommending incarceration and court costs, (2) the court improperly used juvenile adjudications as an aggravating factor, and (3) the new appeal/ineffective-assistance statutes did not preclude this direct appeal.
The Supreme Court of Iowa resolved statutory applicability and nonconstitutional issues, affirmed the sentence, and rejected Boldon’s breach and improper-factor claims.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Boldon)	Held
Applicability of 2019 amendments (Iowa Code §814.6 & §814.7) restricting appeals after guilty plea	The new statutes govern because the right to appeal is determined by the law in effect when judgment is entered	Boldon: his right to appeal vested when plea was accepted before the statutes took effect	Held: Statutes apply; right to appeal is determined by law in effect when judgment/sentence rendered (Damme controlling)
Whether Boldon established "good cause" to appeal from a guilty plea	The State: defendant must show good cause; court should apply Damme standard	Boldon: challenges sentencing (prosecutor breach; improper use of juvenile history) — this constitutes good cause	Held: Good cause exists where defendant challenges sentencing rather than plea; appeal permitted
Whether prosecutor breached the plea agreement (and whether failure to object forecloses review)	State: complied with agreement; recommended concurrent sentences and could argue for incarceration and costs	Boldon: prosecutor undermined bargain by effectively recommending incarceration and costs; counsel ineffective for not objecting	Held: Reviewable on direct appeal; no breach proven — prosecutor recommended concurrent sentences as agreed, did not express material reservations; recommending costs permissible when plea silent (McMurry)
Whether district court improperly considered juvenile adjudications as aggravating factor	State: juvenile adjudications are statutorily permissible to consider under §232.55 and court did not misuse them	Boldon: court treated juvenile history as aggravating without considering mitigating features of youth and thus erred	Held: No error — juvenile adjudications may be considered; Crooks & related juvenile jurisprudence do not require categorical discounting of juvenile records and do not bar consideration of such history absent mandatory-minimum context

Key Cases Cited

State v. Damme, 944 N.W.2d 98 (Iowa 2020) (statute limiting appeals after guilty plea applies to judgments entered on or after effective date)
Santobello v. New York, 404 U.S. 257 (1971) (prosecutorial breach of plea agreement requires remedy even if trial court claims not influenced)
State v. Horness, 600 N.W.2d 294 (Iowa 1999) (failure to follow plea recommendation can taint sentencing; duty to object)
State v. Lopez, 872 N.W.2d 159 (Iowa 2015) (remedy for State breach of plea agreement is vacatur and resentencing before different judge)
State v. Bearse, 748 N.W.2d 211 (Iowa 2008) (prosecutor’s improper use of plea agreements undermines fairness and public confidence)
State v. Fannon, 799 N.W.2d 515 (Iowa 2011) (defense counsel’s failure to object to breach constitutes ineffective assistance in some contexts)
State v. McMurry, 925 N.W.2d 592 (Iowa 2019) (court costs may be imposed where plea agreement is silent)
State v. Crooks, 911 N.W.2d 153 (Iowa 2018) (juvenile mitigating factors must be considered in individualized sentencing, especially with mandatory minimums)