State of Iowa v. Jejuan Tyree Lyke Jr., 16-1473

Lyke pleaded guilty to three felonies arising from a February 3, 2015 incident: intimidation with a dangerous weapon (Class C), willful injury causing bodily injury (Class D), and kidnapping in the third degree (Class C) after a plea agreement that amended and dismissed other charges.
The plea agreement included joint sentencing recommendations: consecutive terms totaling up to 25 years, fines, restitution to be determined, and DNA submission; the information also included gun-enhancement language under Iowa Code § 902.7 for some counts.
At the plea colloquy Lyke admitted moving the victim against his will, bringing the victim into a building to hide/threaten him, and possessing and displaying a handgun to intimidate the victim.
The district court imposed consecutive terms: up to 10 years (intimidation), up to 5 years (willful injury), up to 10 years (third-degree kidnapping), and applied mandatory five-year minimums under Iowa Code § 902.7 for the intimidation and kidnapping counts.
On appeal Lyke raised three principal claims: (1) plea counsel ineffective because no factual basis existed for the kidnapping plea; (2) the dangerous-weapon enhancement on the intimidation count produced an illegal sentence; and (3) plea counsel ineffective for failing to object that the State’s sentencing recommendation breached the plea agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was a factual basis for Lyke’s guilty plea to third-degree kidnapping	Lyke: counsel ineffective because record lacked facts supporting kidnapping elements	State: plea colloquy and charging documents supply sufficient factual basis	Court: Factual admissions at plea (moving victim, secret confinement intent, gun display) supply a factual basis; claim fails
Whether applying the § 902.7 firearm minimum to the intimidation count produced an illegal sentence	Lyke: sentencing enhancement improperly applied to intimidation charge	State: enhancement was alleged in charging papers and plea admitted weapon use, so enhancement applies	Court: Enhancement was statutorily required and properly applied; sentence not illegal
Whether plea counsel was ineffective for not objecting to alleged breach of plea agreement when State sought firearm enhancement	Lyke: counsel should have objected that enhancement breached plea deal	State: plea papers and colloquy did not show a breach; enhancement was included in information and supported by admissions	Court: Record inadequate to show counsel breached duty or prejudice; preserved for possible PCR but no relief on direct appeal

Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (standard for factual basis supporting guilty plea)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (ineffective-assistance claims reviewed de novo)
State v. Rodriguez, 804 N.W.2d 844 (Iowa 2011) (requirement that a factual basis defeats ineffective-assistance challenge to plea)
State v. Lopez, 872 N.W.2d 159 (Iowa 2015) (ineffective-assistance burden: breach and prejudice; consideration on direct appeal when record adequate)
State v. Gordon, 732 N.W.2d 41 (Iowa 2007) (illegal sentence is correctable at any time)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (illegal-sentence standard of review)
State v. Iowa District Court, 308 N.W.2d 27 (Iowa 1981) (application of mandatory five-year weapon enhancement upon admission/ finding of firearm possession)