State of Iowa v. John George Bisdorf Jr., 17-0403

In October 2016 John Bisdorf Jr. was charged with multiple offenses after assaulting his live-in girlfriend; he was later offered reduced aggravated-misdemeanor pleas to domestic abuse assault and first-degree harassment and pled guilty in February 2017.
Bisdorf was represented by court-appointed counsel but repeatedly submitted pro se filings complaining of counsel’s lack of diligence and requesting new counsel, alleging a "total/major breakdown in attorney-client relations."
The district court ordered a competency evaluation; the evaluator found Bisdorf competent and the court found him competent at the time he signed his written guilty pleas.
The court accepted the guilty pleas, adjudicated guilt, and sentenced Bisdorf to two consecutive two-year terms (all but two days suspended) with two years’ probation and fees; Count III was dismissed per the plea agreement.
Bisdorf appealed, arguing the district court violated his Sixth Amendment right by failing to hold an inquiry/hearing on his request for substitute counsel and that his trial counsel was ineffective for not requesting such a hearing and for alleged poor performance (failure to share discovery, take depositions, pressure to plead).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court violated the Sixth Amendment by failing to inquire into/hold a hearing on defendant's requests for new counsel	State: Court’s lack of inquiry doesn’t automatically show a constitutionally significant breakdown; the record contains only defendant’s side and the court’s inquiry would not necessarily change competency/plea validity	Bisdorf: Repeated pro se complaints and statements allege a complete breakdown in communication entitling him to new counsel and a court inquiry/hearing	The court had a duty to inquire, but the record is inadequate on direct appeal to determine whether a complete breakdown occurred; claim preserved for PCR (postconviction relief); convictions affirmed
Whether trial counsel rendered ineffective assistance by failing to request a hearing for substitute counsel and for alleged other deficiencies (discovery, depositions, coercion)	State: Ineffective-assistance claims typically require a fuller record and are better addressed in postconviction proceedings; some claims are foreclosed by a valid guilty plea	Bisdorf: Counsel failed to protect his rights, neglected discovery, pressured him to plead, and failed to move for substitute counsel	Record insufficient on direct appeal to resolve ineffective-assistance claims; preserved for PCR; convictions affirmed

State v. McKinley, 860 N.W.2d 874 (Iowa 2015) (standard for reviewing Sixth Amendment right-to-counsel claims)
State v. Smith, 761 N.W.2d 63 (Iowa 2009) (de novo review of counsel-related constitutional claims)
State v. Tejeda, 677 N.W.2d 744 (Iowa 2004) (duty to inquire when defendant requests substitute counsel due to breakdown in communication)
State v. Webb, 516 N.W.2d 824 (Iowa 1994) (sufficient-cause standard for appointment of substitute counsel)
State v. Lopez, 633 N.W.2d 744 (Iowa 2001) (complete breakdown in communication as sufficient cause)
State v. O’Connell, 275 N.W.2d 197 (Iowa 1979) (ineffective-assistance claims should generally be preserved for postconviction proceedings to allow counsel to rebut)
State v. Mann, 602 N.W.2d 785 (Iowa 1999) (challenges to counsel performance after a valid guilty plea are limited)
State v. LaRue, 619 N.W.2d 395 (Iowa 2000) (ineffective-assistance claims generally fall within challenges preserved after plea)
State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (preference to reserve ineffective-assistance claims for postconviction proceedings)