State of Iowa v. Dustin Allen Heuer
15-2031
| Iowa Ct. App. | Oct 26, 2016Background
- Defendant Dustin Heuer, who has intellectual limitations and a guardian, was charged with second-degree sexual abuse after masturbating in front of children and digitally manipulating a child while at a caregiver’s home.
- Heuer pled guilty on August 31, 2015, following a plea colloquy in which the court and defense counsel discussed the facts, penalties, and competence concerns.
- Defense counsel had a licensed psychologist (Dr. Art Konar) evaluate Heuer; the psychologist reported Heuer understood the facts, could name medications and people involved, and had borderline intellectual functioning.
- Heuer later filed a motion in arrest of judgment claiming duress/coercion, then moved to withdraw that motion and proceed to sentencing; the court accepted the withdrawal after confirming Heuer’s understanding and desire to proceed.
- On appeal Heuer argued (1) the court violated due process by accepting his guilty plea without ordering a competency hearing and (2) counsel was ineffective for allowing the plea and for withdrawing the motion in arrest of judgment.
- The court affirmed, holding there was no basis to order a competency hearing and counsel’s investigation and decisions met professional standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court violated due process by accepting guilty plea without sua sponte competency hearing | No error; record showed no basis to question competence | Heuer lacked competence due to intellectual disability, guardian, and antipsychotic medication | Court: No. Because Heuer’s courtroom demeanor, cooperative responses, and psychologist’s opinion showed present ability to understand and consult with counsel; no competency hearing required |
| Whether counsel was ineffective for allowing an allegedly incompetent client to plead guilty | Counsel acted reasonably: obtained psychological evaluation, investigated defenses, and concluded plea was appropriate | Counsel breached duty by permitting plea despite incompetence | Court: No. Counsel investigated and reasonably concluded Heuer was competent and plea was strategic |
| Whether counsel was ineffective for withdrawing motion in arrest of judgment (duress/coercion) | Withdrawal was reasonable after discussion and court colloquy showing no coercion | Withdrawal prevented challenge to plea entered under duress | Court: No. Counsel researched, discussed matter with Heuer, and reasonably determined duress claim lacked merit |
| Whether appellate error was preserved regarding voluntariness of plea | State: Heuer withdrew motion in arrest of judgment so error not preserved | Heuer asserts due-process exception applies because incompetence would prevent preservation | Court: Preserved in part — applied due-process exception to consider whether competency hearing was required and found none needed |
Key Cases Cited
- State v. Tate, 710 N.W.2d 237 (Iowa 2006) (standards for reviewing guilty plea and ineffective-assistance claims)
- State v. Lucas, 323 N.W.2d 228 (Iowa 1982) (motion in arrest of judgment rule and voluntariness of plea)
- State v. Lyman, 776 N.W.2d 865 (Iowa 2010) (de novo review of competency determinations)
- Dusky v. United States, 362 U.S. 402 (1960) (competency standard: factual and rational understanding and ability to consult with counsel)
- Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance-of-counsel standard)