State of Iowa v. Matthew Schlachter, 15-2074

On August 27, 2014, Schlachter drove a black Chevrolet Colorado at high speed, swerving, and was involved in a multi-vehicle crash causing several serious injuries; one victim was life-flighted and placed on a ventilator.
Officers found drug paraphernalia and methamphetamine residue on Schlachter and obtained blood and urine samples showing amphetamines and opiates.
The State charged Schlachter with three counts of serious injury by vehicle; he entered an Alford plea to one count after plea negotiations.
The district court sentenced Schlachter to five years’ imprisonment; Schlachter appealed, claiming ineffective assistance of counsel and that the court abused its discretion in sentencing.
The appeals court reviewed ineffective-assistance claims de novo and sentencing within statutory limits for abuse of discretion, and examined the record available at the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was a factual basis for Schlachter's Alford plea	State: record (information and minutes) showed serious injury, supporting a factual basis	Schlachter: record did not establish serious injury, so no factual basis for plea	Held: factual basis existed; counsel not ineffective for failing to move in arrest of judgment
Whether counsel was ineffective for failing to advocate for deferred judgment/probation	State: counsel did not breach duty, and even if so, Schlachter suffered no prejudice because such relief was unavailable	Schlachter: counsel should have sought deferred judgment, suspended sentence, or probation	Held: sentencing alternatives barred by statute for intoxication-related serious-injury offense; no prejudice; claim fails
Whether counsel was ineffective for advocating an inapplicable OWI continuum placement	State: placement unavailable; any failure to advocate did not prejudice Schlachter	Schlachter: counsel should have sought OWI continuum placement instead of incarceration	Held: OWI continuum unavailable; no prejudice; claim fails
Whether the district court abused discretion by using a fixed policy in sentencing	Schlachter: court relied on a fixed policy rather than individualized sentencing considerations	State: court considered presentence report, arguments, and the severity of injuries	Held: court considered relevant factors and had little discretion given statutory limits; no abuse of discretion

Strickland v. Washington, 466 U.S. 668 (establishes the two-prong ineffective assistance standard)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (presumption of competent performance; avoid hindsight review)
Schminkey v. State, 597 N.W.2d 785 (Iowa 1999) (court may look to entire record, including minutes of testimony, for factual basis of plea)
Brubaker v. State, 805 N.W.2d 164 (Iowa 2011) (counsel not incompetent for failing to raise meritless issue)
Rouse v. State, 858 N.W.2d 23 (Iowa Ct. App. 2014) (statutory prohibition on suspension/deferred judgment for intoxication-related §707.6A(4) offenses)
North Carolina v. Alford, 400 U.S. 25 (1970) (recognizes guilty pleas without express admissions of guilt)