State of Iowa v. Matthew William Chindlund, 20-1368

In July 2020 Chindlund attacked a CenturyLink employee with a metal pipe, accused him of wiretapping, and took the employee’s work equipment; he was arrested and charged with assault while displaying a dangerous weapon.
While jailed Chindlund damaged jail property and was charged with criminal mischief (third degree).
Jail notes recorded agitation, talking to himself, accusing officers of tapping his lines, requests to see a doctor, and intermittent calmer behavior.
On September 21 Chindlund signed written waivers and submitted paper guilty pleas to both counts, waived personal appearance and motion in arrest of judgment, and asked for immediate sentencing.
Neither Chindlund nor his counsel requested a competency hearing; the district court accepted the paper pleas and sentenced him to concurrent indeterminate terms not to exceed two years on each count.
On appeal Chindlund argued his pleas were not voluntarily and intelligently given due to mental incapacity; the court held he failed to show probable cause that a competency hearing was required and affirmed the convictions and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a competency hearing was required / plea involuntary due to mental incapacity	State: Presumption of competency applies; record did not present probable cause that a mental disorder prevented appreciation, understanding, or assistance; State assumed (without conceding) competency challenge gives good cause to appeal	Chindlund: Jail conduct and notes showing agitation, talking to himself, paranoia and requests to see a doctor show mental incapacity making his paper plea unknowing and involuntary	Court: No specific facts in the record would lead a reasonable person to believe there was a substantial question of competency; defendant failed to meet burden; no sua sponte hearing required; plea stands
Whether inadequate written explanation about concurrent vs consecutive sentences invalidates the plea	State: Claim is barred under Iowa Code § 814.6 because it challenges the plea itself and defendant did not show good cause	Chindlund: Written plea lacked adequate explanation of concurrent vs consecutive sentencing, rendering plea unintelligent	Court: Claim barred under § 814.6; no relief

State v. Einfeldt, 914 N.W.2d 773 (Iowa 2018) (probable-cause standard for ordering competency hearing; reasonable person must believe a substantial question of competency exists)
State v. Tucker, 959 N.W.2d 140 (Iowa 2021) (declined to treat all claims of involuntary pleas as per se good cause to appeal)
State v. Damme, 944 N.W.2d 98 (Iowa 2020) (good-cause exists to appeal pleas when defendant challenges sentence rather than plea)
State v. Walton, 228 N.W.2d 21 (Iowa 1975) (court considers only competency factors known at time of plea)
State v. Lucas, 232 N.W.2d 228 (Iowa 1975) (factors for competency inquiry include irrational behavior, courtroom demeanor, and prior medical opinions)
State v. Mann, 940 N.W.2d 450 (Iowa Ct. App. 2019) (presumption of competency continues unless defendant produces new evidence to the contrary)