State of Iowa v. Robert Earl Brandhorst, 16-1955

At ~3:30 a.m. on July 1, 2015, a deputy followed a vehicle that stopped, reversed, and fled; he located Robert Brandhorst seated in the driver’s seat of a pickup on private property.
Deputy observed beer cans in the vehicle, ran Brandhorst’s license, and arrested him after learning his driving privileges were barred.
Brandhorst was charged with driving while barred as a habitual offender; at trial he argued another person (“Dale”) had been driving. A witness testified seeing a man run across the road.
Brandhorst stipulated that his driving privileges were barred as a habitual offender; the jury convicted him of the charged offense.
Posttrial, Brandhorst moved to dismiss for violation of the one-year speedy-trial rule and later challenged (1) the court’s failure to advise him of rights related to stipulating habitual-offender status and (2) sufficiency of the evidence identifying him as the driver.
The district court denied dismissal and Brandhorst’s appeals; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy-trial dismissal under Iowa R. Crim. P. 2.33(2)(c)	State: defense counsel waived speedy-trial rights by agreeing to a continuance at pretrial conference	Brandhorst: no waiver; counsel’s agreement was to another case, not his	Waiver found; denial of motion to dismiss affirmed
Duty to advise when defendant stipulates to habitual-offender status	State: stipulation was to an element of the offense, not a sentencing enhancement; colloquy not required	Brandhorst: court should have advised him of constitutional rights re: prior convictions per Harrington	Error not preserved; Harrington protections inapplicable to stipulation of an element; claim rejected
Preservation of constitutional challenge to habitual-offender stipulation	State: defendant failed to timely object and preserve error	Brandhorst: contends enhanced sentence is illegal for lack of advisement	Court: claim is an evidentiary/element challenge, not an illegal-sentence claim; error not preserved
Sufficiency of the evidence identifying driver	State: deputy found defendant in driver’s seat, defendant admitted lack of license, keys under seat, passenger side clutter made passenger seating unlikely	Brandhorst: evidence was circumstantial and another person may have been driving	Evidence sufficient; jury could credit deputy’s testimony and convict

State v. Miller, 637 N.W.2d 201 (Iowa 2001) (speedy-trial procedural review and standards)
State v. Elder, 868 N.W.2d 448 (Iowa Ct. App. 2015) (one-year speedy-trial rule exceptions)
State v. Sanford, 814 N.W.2d 611 (Iowa 2012) (sufficiency-of-evidence standard and jury credibility determinations)
State v. O’Connell, 275 N.W.2d 197 (Iowa 1979) (defense counsel may waive speedy-trial rights by requesting continuance)
State v. Everett, 372 N.W.2d 235 (Iowa 1985) (no due-process colloquy required when accepting stipulated factual record)
Tindell v. State, 629 N.W.2d 357 (Iowa 2001) (distinction between procedural error and illegal-sentence claims)
State v. Harrington, 893 N.W.2d 36 (Iowa 2017) (requirements for advisements when prior convictions are used for sentencing enhancements)