State of Iowa v. Goldie Theodore Enochs, 15-1118

On November 16, 2014 Patrick McCoy called police after several armed intruders entered his home; his wife was found bound and intruders asked about money. Surveillance video showed the intruders; McCoy identified Goldie Enochs as one of them. McCoy had been delivering methamphetamine to Enochs and owed him money per Enochs’s claim.
Enochs was charged with first-degree robbery (Iowa Code § 711.2), first-degree burglary (§ 713.3(1)(b)), and going armed with intent (§ 708.8). The State offered a plea: guilty to second-degree robbery and going armed with intent in exchange for dismissal of burglary and a recommendation of consecutive sentences.
At plea colloquy, Enochs admitted entering McCoy’s home intending to steal money, placing occupants in fear, and carrying a handgun with intent to use it; he pleaded guilty to the reduced charges and later received consecutive sentences (10 and 5 years).
On appeal Enochs argued trial counsel was ineffective for allowing him to plead guilty to robbery rather than asserting a claim-of-right defense (that he believed McCoy owed him money), which he contended could negate theft/robbery culpability.
The court evaluated the ineffective-assistance claim under Strickland/State precedent and focused on whether counsel breached an essential duty by not pursuing a claim-of-right defense and foregoing the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the statutory claim-of-right defense applies to robbery or burglary	State: Iowa precedent limits § 714.4 claim-of-right to theft only; it does not extend to robbery or burglary	Enochs: He reasonably believed McCoy owed him money, so claim-of-right would negate robbery culpability	Court: Claim-of-right under § 714.4 is limited to theft and does not apply to robbery or burglary (following State v. Miller and subsequent cases)
Whether counsel was ineffective for allowing guilty plea instead of litigating claim-of-right	State: Defense counsel reasonably declined to raise a foreclosed argument and accepted a favorable plea; competent counsel need not pursue unlikely or foreclosed legal theories	Enochs: Counsel breached an essential duty by not advancing the claim-of-right defense and thus should not have advised acceptance of the plea	Court: Counsel did not breach an essential duty; pursuing claim-of-right was not required given settled Iowa law, so ineffective-assistance claim fails; convictions affirmed

State v. Miller, 622 N.W.2d 782 (Iowa Ct. App. 2000) (holding statutory claim-of-right defense in § 714.4 is limited to theft and does not apply to robbery or burglary)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (standard for evaluating counsel performance using objective reasonableness)
State v. McNeal, 867 N.W.2d 91 (Iowa 2015) (appellate de novo review of ineffective-assistance claims affecting constitutional rights)
Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (defense-performance measured by prevailing professional norms)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
State v. Carroll, 767 N.W.2d 638 (Iowa 2009) (prejudice inquiry when defendant entered a guilty plea requires showing he would have gone to trial)
State v. Fountain, 786 N.W.2d 260 (Iowa 2010) (competent counsel must stay abreast of legal developments but need not predict future changes)
State v. Schoelerman, 315 N.W.2d 67 (Iowa 1982) (competent attorneys need not be "crystal gazers")
State v. Smith, 118 A.3d 49 (Conn. 2015) (out-of-state decision interpreting use-of-force/ownership statutes; discussed by appellant but not controlling)