State of Iowa v. Ryan Lee Markley, 16-1754

Defendant Ryan Markley entered guilty pleas (Alford plea to assault with intent to commit sexual abuse without injury; guilty to second-degree burglary) and appealed convictions and sentences.
Minutes of evidence tied Markley to the scene: his epithelial DNA on the victim’s underwear, the victim’s blood on his jeans, his wallet beneath the exterior window used to enter, his fingerprints on the window, and a boot print; fresh scratch marks on his torso matched the victim’s scratches.
Markley showered after learning police were coming; he agreed the minutes of testimony were generally accurate and that a jury would likely convict if witnesses testified to those minutes.
Markley claimed ineffective assistance of counsel because counsel allowed pleas without a factual basis, and separately argued the sentencing court failed to state adequate reasons for imposing indeterminate and consecutive sentences.
The district court imposed indeterminate terms (assault: up to 2 years; burglary: up to 10 years) and ordered them to be served consecutively.
The Court of Appeals affirmed both the convictions and the sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for allowing guilty/Alford pleas without a factual basis	State: Record (minutes, PSI, defendant statements) supplies sufficient factual basis for both offenses	Markley: No factual basis existed for assault and burglary; counsel erred by permitting the pleas	Affirmed: Entire record provided sufficient factual basis for assault and burglary; no ineffective assistance
Whether sentencing court abused discretion by failing to state reasons for sentence and consecutive terms	State: Court stated reasons (PSI, minutes, plea, prior record, nature of offenses) and may rely on same reasons for consecutives	Markley: Court failed to identify particular facts/circumstances supporting consecutive sentences	Affirmed: Court adequately stated reasons; relying on same reasons for consecutive sentences is permissible

State v. Rodriguez, 804 N.W.2d 844 (Iowa 2011) (standard of review for ineffective-assistance claims)
State v. Ortiz, 789 N.W.2d 761 (Iowa 2010) (factual-basis requirement for guilty pleas)
State v. Gines, 844 N.W.2d 437 (Iowa 2014) (counsel breaches duty by allowing plea absent factual basis)
State v. Schminkey, 597 N.W.2d 785 (Iowa 1999) (prejudice inherent when plea lacks factual basis; sources for factual basis)
State v. Finney, 834 N.W.2d 46 (Iowa 2013) (minutes of evidence can provide factual basis)
State v. Allnutt, 156 N.W.2d 266 (Iowa 1968) (intent may be proved by circumstantial evidence)
State v. Radeke, 444 N.W.2d 476 (Iowa 1989) (when overt acts approach consummation, specific intent to commit sexual abuse may be established)
State v. Philo, 697 N.W.2d 481 (Iowa 2005) (defendant’s on-the-record admissions can supply factual-basis elements)
State v. Hill, 878 N.W.2d 269 (Iowa 2016) (requirement for on-the-record sentencing reasons and use of same reasons for consecutive terms)
North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (Alford plea allows maintaining innocence while acknowledging sufficient evidence for conviction)