State of Iowa v. Kyra J. Williams, 15-2102

Kyra Williams was charged with first-degree robbery and conspiracy to commit a forcible felony; she pleaded guilty to conspiracy under a plea agreement.
Under the plea deal the State dismissed the robbery charge, agreed to recommend against incarceration, and Williams agreed to cooperate against two co-defendants.
The district court accepted the guilty plea and sentenced Williams to a ten-year suspended sentence with two years probation, restitution, fees, and costs.
At sentencing the prosecutor stated the State would recommend suspension of the ten-year term and two years probation but emphasized the seriousness of the offense and described Williams’s more limited role versus her co-defendants.
Williams appealed, claiming trial counsel was ineffective for not objecting to the prosecutor’s sentencing remarks, arguing those remarks breached the spirit of the plea agreement and undercut the promise to recommend against incarceration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prosecutor breached the plea agreement by undercutting the agreed recommendation against incarceration	The State argued it complied: it recommended suspension/probation as promised and merely provided context for that recommendation	Williams argued the prosecutor’s emphasis on severity and co-defendants’ conduct violated the spirit of the plea deal and effectively advocated for harsher punishment	Court held no breach: the prosecutor recommended the agreed sentence, provided contextual justification, and did not urge a harsher sentence
Whether trial counsel was ineffective for failing to object to the prosecutor’s remarks	State argued counsel cannot be ineffective where no breach occurred	Williams argued counsel should have objected to protect the plea bargain	Court held counsel was not ineffective because there was no State breach
Whether the record is adequate to decide ineffective-assistance claim on direct appeal	State argued record supported decision on direct appeal	Williams would prefer postconviction review	Court found the record adequate and decided the claim on direct appeal
Whether the prosecutor was required to advocate for a lesser sentence than in the plea agreement	State argued no obligation to favor a sentence more lenient than the plea	Williams argued prosecutor’s conduct implied a lesser advocacy duty	Court held prosecutor need only recommend and approve the agreed sentence, not argue for a lesser one

State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (standard of review for ineffective-assistance claims and framework for plea-agreement breaches)
State v. Bearse, 748 N.W.2d 211 (Iowa 2008) (requirements for addressing ineffective-assistance claims on direct appeal)
State v. Horness, 600 N.W.2d 294 (Iowa 1999) (prosecutor breaches plea agreement by recommending a different sentence than promised)
State v. Frencher, 873 N.W.2d 281 (Iowa Ct. App. 2015) (contextual discussion of prosecutor comments does not necessarily show breach)