State of Iowa v. Hubert Todd Jr., 16-0149

Hubert Todd Jr. pleaded guilty to second-offense domestic abuse assault (alleged March 7, 2015) and signed a written plea agreement on December 21, 2015; judgment and sentence entered December 22, 2015.
At filing and sentencing a no-contact order with the victim (his wife Lola) was in place and the plea agreement and sentence extended that no-contact order for five years.
Todd later asserted he did not know the five-year no-contact extension was part of the plea agreement, moved to withdraw his guilty plea (Dec. 30), and the motion was denied (Jan. 3).
Multiple efforts were made to modify the no-contact order; limited contact (telephone/written) was permitted while Todd was in prison; the no-contact order was ultimately cancelled by court order on July 16, 2016.
Todd also claimed ineffective assistance of counsel (counsel added to or failed to explain the plea) and raised constitutional arguments about the no-contact order; the district court denied relief and Todd appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of no-contact order challenge	State: no-contact order cancelled, issue moot	Todd: challenges tied to sentence and plea validity	Court: challenge to no-contact order is moot because order was later cancelled
Whether plea should be withdrawn	State: plea and sentence conform to plea agreement; no altered terms	Todd: plea included five-year no-contact addition unknown to him; plea was involuntary	Court: no abuse of discretion denying withdrawal; record shows no deviation between agreement and sentence
Preservation of appeal rights after guilty plea	State: guilty plea waives defenses; must file motion in arrest of judgment; waiver limits appeals	Todd: argues exception where sentence deviates from plea applies	Court: recognizes waiver rule but applies Malone exception only if sentence deviates; no deviation here
Ineffective assistance of counsel	State: record inadequate to resolve on direct appeal	Todd: counsel added terms or failed to advise him of plea contents	Court: claim preserved for postconviction relief; direct appeal record insufficient to resolve

Homan v. Branstad, 864 N.W.2d 321 (Iowa 2015) (definition of mootness and justiciable issues)
In re E.C.G., 345 N.W.2d 138 (Iowa 1984) (considering broad consequences when assessing mootness)
State v. Antenucci, 608 N.W.2d 19 (Iowa 2000) (guilty plea generally waives defenses; need for motion in arrest of judgment)
State v. Malone, 511 N.W.2d 423 (Iowa 1993) (exception when sentence does not conform to plea agreement)
State v. Speed, 573 N.W.2d 594 (Iowa 1998) (standard of review for denial of motion to withdraw guilty plea)
State v. Straw, 709 N.W.2d 128 (Iowa 2006) (preservation rules for ineffective-assistance claims)
State v. Coil, 264 N.W.2d 293 (Iowa 1978) (ineffective assistance generally preserved for postconviction relief)
State v. McCright, 569 N.W.2d 605 (Iowa 1997) (constitutional issues not raised at trial cannot be raised first on appeal)
State v. Wages, 483 N.W.2d 325 (Iowa 1992) (same principle regarding preservation of issues for appeal)