State of Iowa v. Walter Baylor, 14-1856

Walter Baylor pleaded guilty to possession of marijuana with intent to deliver; plea was subject to court concurrence and enhanced as a habitual offender.
After plea, defense counsel filed a motion in arrest of judgment seeking withdrawal of the plea, initially asserting Baylor was not informed of effects on pending Illinois charges.
At the motion hearing Baylor raised dissatisfaction with counsel, claiming counsel failed to take depositions or move to suppress and saying he felt rushed and innocent; he requested substitute counsel for sentencing.
The district court heard Baylor, defense counsel, and the prosecutor (who characterized Baylor’s requests as delay tactics) and denied substitution and the motion in arrest of judgment.
The court accepted the plea agreement at sentencing and imposed the agreed sentence; Baylor appealed raising three main claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substitute counsel request at sentencing	State: denial preserved; court balanced delay concerns and counsel competence	Baylor: court failed duty to inquire and appoint new counsel after communication breakdown	Denial not an abuse of discretion; court adequately heard parties and could deny as last-minute/delay tactic
Motion in arrest of judgment (withdraw plea)	State: plea colloquy complied with rule 2.8 and finality should stand	Baylor: plea involuntary due to poor counsel communication/failure to investigate; wanted suppression/depositions	Denial not an abuse of discretion; written motion raised only collateral Illinois consequence and plea colloquy satisfied rule 2.8(2)(b)
Sentencing explanation requirement	State: followed plea agreement; reasons unnecessary when court gives effect to agreement	Baylor: court abused discretion by not stating reasons for incarceration on record	No abuse; sentence implemented plea agreement so any omission was harmless; record shows court followed agreement
Ineffective-assistance claim preservation	State: appeal preserved other issues	Baylor: counsel’s pre-plea omissions rendered plea unknowing	Claim preserved for postconviction relief because record inadequate to resolve ineffective-assistance on direct appeal

State v. Tejeda, 667 N.W.2d 744 (Iowa 2004) (court’s duty to inquire when defendant requests substitute counsel)
United States v. Seale, 461 F.2d 345 (7th Cir. 1972) (court must rule when accused voices complaint about counsel)
State v. Lopez, 633 N.W.2d 774 (Iowa 2001) (standard for substitute counsel: sufficient cause and balancing delay/public interest)
State v. Hallock, 765 N.W.2d 598 (Iowa Ct. App. 2009) (court not required to inform defendant of collateral consequences of plea)
State v. Antenucci, 608 N.W.2d 19 (Iowa 2000) (guilty plea in conformity with rule 2.8 waives defenses)
State v. LaRue, 619 N.W.2d 395 (Iowa 2000) (finality of guilty plea and expectation of conviction finality)
State v. Smith, 753 N.W.2d 562 (Iowa 2008) (standard of review for denial of motion in arrest of judgment)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (preserving ineffective-assistance claims for postconviction relief when record inadequate)
State v. Cason, 532 N.W.2d 755 (Iowa 1995) (when court simply gives effect to plea agreement, sentencing discretion is not exercised)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (need for plea-agreement terms in record to determine whether court exercised sentencing discretion)
State v. Thompson, 856 N.W.2d 915 (Iowa 2014) (rule requiring court to state reasons for sentence and noting comment when discretion lacking)