State of Iowa v. Lara L. Welch, 16-1304

Hudson officer ran a plate check and discovered the vehicle’s registered owner (age 77) had an expired license; the driver was younger and identified as Lara Welch, the owner’s daughter.
Officer engaged Welch, developed reasonable suspicion of impairment, and arrested her for operating while intoxicated (first offense).
Welch moved to suppress evidence, arguing the officer lacked reasonable suspicion to continue the stop after determining she was not the registered owner.
District court denied suppression, relying on State v. Jackson; Welch pleaded guilty and thereby (generally) waived suppression challenges.
After Welch’s plea, the Iowa Supreme Court decided State v. Coleman, overruling Jackson and holding traffic stops must end once reasonable suspicion is gone.
Welch claimed trial counsel was ineffective for allowing the guilty plea and waiver of the suppression claim; the court affirmed the conviction but preserved the ineffective-assistance claim for postconviction proceedings due to an inadequate record on direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer lawfully continued the traffic stop after learning the driver was not the registered owner	Officer’s minimal check of driver ID after a lawful stop was permissible under prior precedent (Jackson) and routine traffic enforcement	Continued detention lacked reasonable suspicion under Coleman; stop should have ended when original purpose dispensed	Court affirmed district court (denied suppression) but acknowledged Coleman overruled Jackson and changed law; suppression challenge effectively waived by guilty plea on record before Coleman
Whether Welch’s guilty plea waived suppression challenge	A guilty plea waives defenses not intrinsic to plea (Carroll)	Plea should not bar review where law changed after plea and counsel may have been ineffective	Court held plea waived suppression claim on direct appeal but preserved ineffective-assistance claim for collateral review due to inadequate record
Whether trial counsel was ineffective for allowing plea that waived suppression claim	Counsel reasonably relied on existing precedent (Jackson) at time of plea	Counsel was ineffective for allowing waiver in light of Coleman and should be allowed to pursue relief	Court expressed doubt Welch could prevail on ineffective-assistance on direct appeal but preserved the claim for postconviction-relief proceedings (record inadequate to resolve now)

State v. Coleman, 890 N.W.2d 284 (Iowa 2017) (traffic stop must end when reasonable suspicion no longer present; overruled Jackson)
State v. Jackson, 315 N.W.2d 766 (Iowa 1982) (officer may check driver’s license after lawful stop)
State v. Carroll, 767 N.W.2d 638 (Iowa 2009) (guilty plea waives non-intrinsic defenses and objections)
State v. Toles, 885 N.W.2d 407 (Iowa 2016) (ineffective-assistance claim on direct appeal requires adequate record)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (court must preserve ineffective-assistance claims when record is inadequate)