Daughenbaugh v. State
Annotate this CaseAppellant David Daughenbaugh pled guilty to criminal charges in exchange for the State's promise not to oppose Appellant's request for a deferred judgment. The district court accepted Appellant's request for a deferred judgment, placed him on supervised probation, and imposed civil penalties. Appellant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The State filed a motion for summary judgment, asserting that Appellant had not been "convicted" for purposes of postconviction relief. The district court held (1) Appellant was entitled to file a claim for postconviction relief because Appellant's guilty pleas amounted to convictions even though he received a deferred judgment; and (2) counsel was not ineffective. The Supreme Court affirmed but for different reasons, holding (1) a guilty plea pursuant to a deferred judgment is not a "conviction" under Iowa's postconviction statute; and (2) therefore, Appellant was not entitled to postconviction relief.
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