Tyson James Ruth v. State of Iowa, 20-0125

Tyson Ruth appealed the denial of his application for postconviction relief (PCR) after pleading guilty pursuant to a plea deal.
Ruth claimed trial counsel was ineffective for (1) allowing an allegedly coerced/unvoluntary plea and (2) failing to file a suppression motion challenging search warrants issued by a magistrate with an asserted conflict of interest.
Ruth asserted he would have gone to trial if counsel had filed the suppression motion, but he offered no factual or legal defenses to the underlying charges.
The magistrate had previously represented Ruth’s father in a guardianship proceeding and had other limited ties to Ruth’s family; she testified her relationships did not affect her warrant determinations.
At the PCR hearing, counsel testified he investigates viable suppression grounds and would have looked into a conflict if made aware; the district court found counsel more credible than Ruth.
The court applied the Strickland standard and concluded Ruth failed to prove deficient performance or prejudice, affirming the denial of PCR.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for allowing a coerced/unvoluntary guilty plea by failing to file a suppression motion	Ruth: counsel failed to file the requested suppression motion, so his plea was not knowing or voluntary and he would have gone to trial	State: plea was voluntary on the record; Ruth offered no defense or reason to reject the plea; argument is boilerplate and waived	Court: Waived/insufficient; plea is presumptively voluntary and Ruth failed to overcome presumption; no ineffective assistance shown
Whether counsel was ineffective for failing to challenge search warrants based on magistrate conflict of interest	Ruth: magistrate had prior representation of his father and ties to family; counsel should have moved to suppress	State: counsel testified he would investigate known conflicts; no evidence counsel knew of any conflict; magistrate testified she acted independently	Court: No deficient performance shown; even assuming breach, Ruth failed to show prejudice or that a different magistrate would have produced a different result

Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance two‑prong standard of performance and prejudice)
State v. Lopez, 907 N.W.2d 112 (Iowa 2018) (discusses ineffective-assistance framework in Iowa)
Dunbar v. State, 515 N.W.2d 12 (Iowa 1994) (requires specific allegations showing how competent counsel would have changed outcome)
State v. Nosa, 738 N.W.2d 658 (Iowa Ct. App. 2007) (plea hearing record creates a presumption of voluntariness)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (arguments lacking legal development may be deemed waived)
State v. McNeal, 897 N.W.2d 697 (Iowa 2017) (court may address either prong of ineffective-assistance test first)