State of Iowa v. Derrick Justin Green, 16-0059

Derrick Green was charged with OWI (third offense) on January 21, 2015 and entered a guilty plea under a plea agreement (State would not seek habitual enhancement).
The district court accepted Green’s guilty plea and sentenced him to an indeterminate term not to exceed five years, plus costs, fees, and a fine.
Green did not file a motion in arrest of judgment before appealing; the court informed him such a motion was necessary to challenge the plea but did not explain it preserved error for appeal.
On appeal Green argued his guilty plea was not knowingly, voluntarily, and intelligently entered, focusing on alleged inadequate colloquy regarding waiver of the right to a jury trial.
The appellate court reviewed plea challenges for errors at law and applied the substantial compliance standard for Iowa R. Crim. P. 2.8(2)(b).
The court found the district court’s colloquy — which informed Green that pleading guilty waives a speedy public jury trial and requires a unanimous 12-member verdict for conviction — substantially complied with rule requirements and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Green’s guilty plea was voluntarily and intelligently entered under Iowa R. Crim. P. 2.8(2)(b)	State: court substantially complied with plea-colloquy requirements; plea valid	Green: court’s colloquy about jury-trial waiver was inadequate, so plea not knowing/voluntary	Affirmed — plea was voluntarily and intelligently entered under substantial compliance standard
Whether the court adequately advised Green of his right to a jury trial	State: court informed Green he waived a speedy, public trial and unanimity requirement	Green: court failed to cover all Liddell factors (e.g., participation in jury selection)	Affirmed — colloquy sufficiently informed Green of jury-right waiver despite not covering every Liddell factor
Whether lack of a motion in arrest of judgment precludes appellate review	State: defendant did not file motion; normally required to preserve error	Green: court’s incomplete advisement allows appeal despite no motion filed	Court allowed appeal because trial court did not fully explain motion-in-arrest requirement
Standard for reviewing adequacy of plea colloquy	State: apply substantial compliance standard	Green: argues more exacting compliance needed for jury-waiver advisement	Court applied substantial compliance and found requirements met

State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (motion in arrest of judgment generally required to preserve plea-challenge error)
State v. Taylor, 301 N.W.2d 692 (Iowa 1981) (substantial compliance standard for plea-rule requirements)
State v. Loye, 670 N.W.2d 141 (Iowa 2003) (defendant must be informed of matters in rule and understand them)
State v. Liddell, 672 N.W.2d 805 (Iowa 2003) (factors illustrating sufficiency of informing defendant about jury-trial rights)
State v. Meron, 675 N.W.2d 537 (Iowa 2004) (trial court must advise defendant that a motion in arrest of judgment is necessary to challenge plea adequacy)