State v. Steiger

Under the circumstances of this case, Defendant was denied procedural protections for determining his status as an habitual offender at trial, and Defendant did not need to preserve error by filing a motion in arrest of judgment.After a bench trial, Defendant was convicted of indecent exposure and sentenced as a habitual offender. Defendant also pled guilty to indecent exposure. On appeal, the State conceded that the plea colloquy was insufficient. However, contrary to Defendant’s arguments, the State argued that the stipulation relating to Defendant’s prior convictions was sufficient. The court of appeals concluded that Defendant failed to preserve error on his claim that the stipulation concerning his prior convictions was deficient and that Defendant was required to challenge the sufficiency of the proceedings either by filing a motion in arrest of judgment or by another means. The Supreme Court vacated the decision of the court of appeals and reversed the judgment and sentences of the district court, holding (1) requirements of the enhanced-penalty hearing were not followed by the district court; and (2) the error preservation rule established in State v. Harrington, 893 N.W.2d 36 (Iowa 2017) was not in existence at the time. View "State v. Steiger" on Justia Law