State of Iowa v. Lucas Benjamin Leonhard, 16-1318

On Nov. 10, 2015 Louisa County deputies attempted a traffic stop of a Nissan driven by Lucas Leonhard, who accelerated and fled at high speed (127+ mph in a 55 mph zone); stop sticks disabled the car and Leonhard was arrested.
Officers found controlled substances (disputed as methamphetamine vs. marijuana) in the vehicle; Leonhard was charged with eluding as a Class D felony under Iowa Code §321.279(3)(b) (alleging possession of a controlled substance during the eluding) and with driving while revoked.
Leonhard pleaded guilty to eluding (without habitual-offender enhancement); the State dismissed the revocation charge. Both parties agreed incarceration was appropriate.
During plea colloquy the parties clarified the controlled substance was marijuana; Leonhard affirmed he exceeded the speed threshold and possessed marijuana while eluding. He expressed satisfaction with counsel and understanding of the plea.
After the plea, Leonhard filed a motion in arrest of judgment claiming inadequate counsel and that he had lied during the plea because he felt compelled to say yes; the court personally questioned him and denied the motion, concluding a sufficient factual basis existed and no substitute counsel was required.
Leonhard appealed, arguing (1) the plea lacked a factual basis and (2) the court violated his Fifth and Sixth Amendment rights by failing to appoint substitute counsel sua sponte for his motion in arrest of judgment.

Issue	State's Argument	Leonhard's Argument	Held
Was there a sufficient factual basis for the guilty plea to eluding under §321.279(3)(b)?	Leonhard’s in-court admissions (and stipulation to marijuana) provided the required factual basis.	Plea lacked factual basis because of confusion over methamphetamine vs. marijuana and because he later said he lied during colloquy.	Held: Sufficient factual basis; defendant’s statements during colloquy support the element of possession of a controlled substance.
Did Leonhard preserve or merit appointment of substitute counsel for his motion in arrest of judgment?	Court fulfilled duty by personally questioning Leonhard; no request for new counsel and no showing of severe breakdown in communication.	Counsel was inadequate and did not fully explain trial alternatives; alleged inability to make informed plea warranted new counsel.	Held: No abuse of discretion; substitution not required and court’s inquiry was adequate.

State v. Smith, 753 N.W.2d 562 (Iowa 2008) (standard for reviewing motion in arrest of judgment)
State v. Keane, 630 N.W.2d 579 (Iowa 2001) (trial court must find factual basis for guilty plea)
State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (sources for factual basis may include defendant’s plea colloquy)
State v. LaRue, 619 N.W.2d 395 (Iowa 2000) (waiver of defenses upon voluntary guilty plea)
Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (voluntariness and intelligence of guilty plea)
State v. Boone, 298 N.W.2d 335 (Iowa 1980) (definition of voluntary and intelligent plea)
State v. Tejada, 677 N.W.2d 744 (Iowa 2004) (court’s duty to inquire about counsel performance and review standard for substitute counsel)
State v. Webb, 516 N.W.2d 824 (Iowa 1994) (sufficient reasons required for substitution of counsel)
Smith v. Lockhart, 923 F.2d 1314 (8th Cir. 1991) (examples of sufficient reasons for substitution)
United States v. Lott, 310 F.3d 1231 (10th Cir. 2002) (defining "breakdown in communication" standard)