State of Iowa v. Kristy Danae Rattray, 15-1092

Police executed a search warrant at a Des Moines residence occupied by six people and found 14.3 grams of methamphetamine. Rattray was charged with possession with intent to deliver (over 5 grams) and failure to possess a tax stamp.
The State filed notices of additional witnesses and obtained a continuance of the scheduled trial over Rattray’s objection; Rattray later accepted a plea offer and pled guilty to a lesser-included possession offense and the tax-stamp charge.
Minutes of testimony reported multiple witnesses identifying Rattray as living in the bedroom where at least 7.5 grams of methamphetamine were found, purchases from Rattray, and a purse in the bedroom containing ~2.2 grams; Rattray admitted possession and lack of a tax stamp at the plea hearing.
At sentencing the court imposed consecutive sentences (10 years and 5 years maximum), suspended them, and placed Rattray on three years’ probation; Rattray appealed asserting ineffective assistance and sentencing error.
The appellate court reviewed ineffective-assistance claims de novo and sentencing for abuse of discretion, and preserved some ineffective-assistance claims for postconviction relief due to an inadequate record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for allowing plea without sufficient factual basis	State: minutes and admissions provided factual basis supporting plea	Rattray: record lacked evidence she possessed or knew of the drugs and possessed ≥7 grams	Court: factual basis sufficient; counsel not ineffective on this ground
Whether plea was not knowing, voluntary, and intelligent due to counsel's performance	State: plea colloquy included admissions; no record showing coercion or deficiency	Rattray: counsel failed to ensure plea was knowing/voluntary	Court: record inadequate to resolve on direct appeal; preserved for PCR
Whether counsel failed to correct court's mistaken belief that plea recommended consecutive sentences	State: parties told court they would recommend consecutive sentences though court free to impose any disposition	Rattray: court relied on erroneous understanding of plea terms	Court: no evidence court’s understanding was incorrect; consecutive sentences not an abuse of discretion
Whether district court abused discretion by denying deferred judgment	State: court considered statutory factors and sentencing options	Rattray: court failed to consider or mention deferred judgment	Court: court explicitly considered options and factors; not an abuse of discretion

State v. Philo, 697 N.W.2d 481 (Iowa 2005) (ineffective-assistance claims may be raised on direct appeal and reviewed de novo)
State v. Tompkins, 859 N.W.2d 631 (Iowa 2015) (two-prong Strickland framework applied in Iowa)
State v. Ambrose, 861 N.W.2d 550 (Iowa 2015) (court may resolve ineffective-assistance claims under either Strickland prong)
State v. Velez, 829 N.W.2d 572 (Iowa 2013) (factual basis required for guilty plea; sources to evaluate include minutes, plea hearing statements, PSI)
Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (record need only demonstrate facts supporting elements of the offense)
State v. Dudley, 766 N.W.2d 606 (Iowa 2009) (counsel not required to raise meritless issues)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (inadequate record may require preservation of claims for postconviction relief)
State v. Hopkins, 860 N.W.2d 550 (Iowa 2015) (sentencing reviewed for abuse of discretion; sentence within statutory limits presumed valid)
State v. Leckington, 713 N.W.2d 208 (Iowa 2006) (abuse of discretion standard described)
State v. Thomas, 547 N.W.2d 223 (Iowa 1996) (sentencing court must state reasons for sentence but need not explain rejection of alternatives)