State of Iowa v. Stacy Leigh Rook
17-0002
| Iowa Ct. App. | Sep 27, 2017Background
- Stacy Rook pleaded guilty in 2014 to possession of pseudoephedrine; received a two-year deferred judgment and probation with drug-abstinence and testing conditions.
- DCS filed multiple violation reports documenting repeated positive drug tests, missed/failed drug tests, discovery of paraphernalia, and an assault charge; Rook admitted substance use to her probation officer.
- Rook attended inpatient and outpatient VA substance-abuse treatment in 2016; VA clinician submitted a letter describing diagnoses and treatment.
- The State filed an application for adjudication of guilt and sentencing; at the revocation hearing Rook, with counsel, stipulated to the allegations after a court colloquy confirming her rights and voluntariness and after a recess to review the reports with counsel.
- The district court found Rook willfully violated probation, revoked the deferred judgment, adjudicated guilt, suspended a sentence up to five years, and placed Rook on probation with residential-treatment conditions.
- Rook appealed alleging ineffective assistance of counsel for (1) failing to verify a factual basis / ensure a knowing, voluntary stipulation and (2) failing to investigate mental-health mitigation/diminished capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was counsel ineffective for not ensuring the stipulation had a factual basis and was knowing/voluntary? | State: Rook knowingly and voluntarily stipulated after court advisements and counsel review; record supports facts. | Rook: Counsel failed to verify factual basis and ensure stipulation was knowing, intelligent, voluntary (citing Rhoades). | Court: No — revocation based on Rook’s unqualified admissions and record support; Rhoades (guilty-plea context) inapplicable. |
| Was counsel ineffective for failing to investigate mental-health issues to pursue diminished-capacity defense? | State: Mental-health information was in the record (VA letter, testimony); counsel not ineffective for failing to pursue meritless strategy. | Rook: Counsel did not adequately investigate her mental-health history to avoid revocation. | Court: No — record contained VA documentation and testimony; counsel not ineffective. |
| Were Rook’s due-process rights at the revocation hearing violated? | State: Court complied with Morrissey requirements; Rook waived any additional rights by stipulation. | Rook: Implied challenge to adequacy of procedure by attacking counsel’s performance. | Court: No due-process violation: required warnings given; rights may be waived and were here. |
| Should ineffective-assistance claim be preserved or decided on record? | State: Record adequate to decide claim on direct appeal. | Rook: Claims raised on appeal; some issues were unpreserved at trial. | Court: Resolved claims on the record; preserved/preserved-as-applicable (noted some arguments unpreserved). |
Key Cases Cited
- Morrissey v. Brewer, 408 U.S. 471 (due process minimums for probation revocation)
- Gagnon v. Scarpelli, 411 U.S. 778 (probation revocation is not a stage of criminal prosecution)
- Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (factual-basis requirement for guilty pleas)
- Thorndike, 860 N.W.2d 316 (Iowa) (standard of review for ineffective-assistance claims)
- Schaer v. State, 757 N.W.2d 630 (Iowa) (no duty to raise meritless issues)
- Bearse v. State, 748 N.W.2d 211 (Iowa) (counsel not ineffective for failing to raise meritless objections)
- Howse, 875 N.W.2d 684 (Iowa) (preservation rules for appellate review)