State of Iowa v. Robin Eugene Brubaker, 805 N.W.2d 164

Brubaker was convicted of operating while intoxicated (OWI), fourth offense, and unlawful possession of a prescription drug under Iowa Code 155A.21(1).
Officers searched Brubaker's car after arrest without a warrant, arguing it was a search incident to arrest in a cluttered interior.
A criminalist testified pills found in Brubaker's car were “consistent in appearance” with clonazepam, a Schedule IV prescription drug.
The State did not test the pills or call a qualified expert to confirm they were clonazepam; testimony relied on appearance and reference materials.
The court treated the insufficiency of evidence to prove the pills were clonazepam as dispositive, and Brubaker’s trial counsel failed to preserve a specific grounds objection at trial.
The court reversed the unlawful possession conviction and remanded for dismissal of that charge, and held counsel was ineffective for not raising the specific sufficiency issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the pills were proven to be clonazepam beyond reasonable doubt	Brubaker	Brubaker	Insufficient evidence to prove pills were clonazepam; conviction reversed and charge dismissed
Whether trial counsel was ineffective for not asserting a specific insufficiency objection	Brubaker	Brubaker	Counsel ineffective; prejudice shown; remand for dismissal of the charge

State v. Truesdell, 679 N.W.2d 611 (Iowa 2004) (preservation of sufficiency-error requires specific grounds for acquittal)
State v. Vance, 790 N.W.2d 775 (Iowa 2010) (ineffective-assistance claims may be raised on direct appeal in some cases)
State v. Soboroff, 798 N.W.2d 1 (Iowa 2011) (postconviction relief normally used; direct appeal possible when record adequate)
State v. Coil, 264 N.W.2d 293 (Iowa 1978) (preserves claims to respond to defendant’s claims; record development concern)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (tests for ineffective assistance: deficient performance and prejudice)