State of Iowa v. Preston Roby, 16-0192

Roby was charged with OWI, second offense, and driving while barred, both aggravated misdemeanors, in Black Hawk County, Iowa.
On October 29, 2015, Roby entered written guilty pleas admitting operation while intoxicated and license bar on May 15, 2015, and a prior OWI conviction in 2007.
The district court imposed concurrent sentences: 180 days with all but 7 suspended for OWI, and 21 days for driving while barred.
There was no transcript or verbatim record of Roby’s guilty-plea proceeding.
Roby’s counsel did not file a motion in arrest of judgment challenging the validity of the guilty pleas.
The court affirmed the convictions and preserved Roby’s challenge to the guilty pleas for postconviction-relief proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failure to file motion in arrest of judgment	Roby (State) argues counsel failed essential duty.	Roby contends procedures violated rules 2.8 and 2.10, affecting validity of pleas.	Record inadequate; preserve for postconviction relief; conviction affirmed.
Preservation and adequacy of record on direct appeal	State maintains no need to address plea validity on direct appeal.	Record is incomplete; cannot adjudicate merits on direct appeal.	Record inadequate; claim preserved for postconviction relief.

State v. Straw, 709 N.W.2d 128 (Iowa 2006) (ineffective assistance standards on direct appeal")
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (de novo review for ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (Supreme Court 1984) (establishes deficient performance and prejudice elements)
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (prejudice showing required for relief)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (record inadequate to address claim on direct appeal; preserve for postconviction relief)
State v. Hallock, 765 N.W.2d 598 (Iowa Ct. App. 2009) (defendant must show reasonable probability of trial if guilty plea not entered)