State of Iowa v. Jennifer Lynn Tucker
959 N.W.2d 140
| Iowa Ct. App. | 2021Background:
- Police searched Tucker’s home and found ~21.92g methamphetamine (in purse) and ~27.95g heroin (in closet); she was charged with two drug counts (intent to deliver) and separately with third-degree burglary.
- Prosecutor emailed a plea offer: if Tucker "work[ed] with the Task Force" and proffered, the State would dismiss the drug charges; separately, if she proffered and testified against Weaver, State would offer a plea to third-degree burglary with suspended-sentence recommendations.
- Tucker sat for a proffer with drug task force deputies and testified at Weaver’s first burglary trial (which ended in a hung jury); she later absconded, missed the retrial, was arrested, tried on the drug charges, and convicted.
- At a post-conviction hearing Tucker moved to dismiss and enforce the plea agreement, arguing she fulfilled the drug-case obligation by proffering; the State argued she failed to fully cooperate (e.g., controlled buys, continued CI activity) and that obligations across the two matters were tied.
- The district court denied the motion; on appeal the Iowa Court of Appeals concluded the written email agreement did not impose the broader, unwritten task-force obligations or tie the burglary and drug-case duties together, found the State breached, granted specific performance, vacated convictions, and remanded for dismissal of the drug charges.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tucker fulfilled the plea-agreement condition to "work with the Task Force" entitling her to dismissal of the drug charges | State: "work with" meant ongoing CI activity (controlled buys, calls); Tucker later absconded so she breached | Tucker: Agreement required only that she proffer/meet with task force; she did so, so State must dismiss drug charges | Tucker performed as agreed; State breached by not dismissing. Specific performance granted; drug charges to be dismissed |
| Whether the drug-case dismissal was conditioned on Tucker’s full performance in the separate burglary agreement (i.e., testimony at retrial) | State: The two promises formed a comprehensive, tied agreement; failure to perform in one case vitiates the other | Tucker: The email created separate obligations for each case; burglary performance does not affect drug dismissal | Agreements are separate; ambiguities construed against the State. Burglary performance not a condition for drug dismissal |
| Other issues raised at trial (sufficiency of evidence; reasons for consecutive sentences) | State: convictions and sentences were proper | Tucker: insufficiency and failure to state reasons for consecutives | Not reached due to disposition ordering dismissal of drug charges |
Key Cases Cited
- State v. Beres, 943 N.W.2d 575 (Iowa 2020) (plea bargains treated like contracts; standard of review for plea-repudiation dismissal)
- State v. Horness, 600 N.W.2d 294 (Iowa 1999) (prosecutor promises that induce pleas must be fulfilled; strict standards for promise and performance)
- State v. Foy, 574 N.W.2d 337 (Iowa 1998) (State bears burden to prove defendant failed to perform under plea agreement)
- Iowa Fuel & Minerals, Inc. v. Iowa State Bd. of Regents, 471 N.W.2d 859 (Iowa 1991) (contract ambiguities are construed against the drafter)