State of Iowa v. Loren Anton Goodwin, 16-1407

Loren Goodwin pleaded guilty to operating a motor vehicle while barred as a habitual offender; plea agreed May 13, 2016 with State recommending 90 days work release.
Written plea form disclosed statutory maximum prison term and minimum/maximum fine but did not disclose the mandatory chapter 911 surcharge applicable to fines.
District court sentenced Goodwin to one year in jail with all but 90 days suspended and suspended the fine and surcharge.
Goodwin challenged his plea on appeal, arguing it was not knowing and voluntary because he was not informed of the mandatory surcharge.
The State conceded the motion-in-arrest-of-judgment advisory was inadequate, so the appellate court permitted direct review of the plea challenge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Goodwin’s guilty plea substantially complied with Iowa R. Crim. P. 2.8(2)(b)(2) despite omission of mandatory surcharge	The State conceded inadequate advisory on motion-in-arrest and argued plea otherwise valid	Goodwin argued omission of mandatory surcharge misstated maximum/minimum punishment, rendering plea unknowing and involuntary	Court held plea did not substantially comply because omission of mandatory surcharge misinformed Goodwin about potential fines; plea vacated and remanded

State v. Fisher, 877 N.W.2d 676 (Iowa 2016) (defendants must be informed of surcharges as part of maximum possible punishment under rule 2.8(2)(b)(2))
State v. Myers, 653 N.W.2d 574 (Iowa 2002) (substantial-compliance standard; defendant must be made aware of rights though exact wording not required)
State v. Meron, 675 N.W.2d 537 (Iowa 2004) (substantial compliance requires essence of each rule requirement be expressed)
State v. Kress, 636 N.W.2d 12 (Iowa 2001) (failure to inform defendant about possible increases to punishment is tantamount to failing to advise on maximum possible punishment)