review from the Iowa Court of Appeals.
from the Iowa District Court for Scott County, Douglas C.
McDonald and Christine Dalton Ploof, Judges.
seeks further review of a court of appeals decision affirming
the district court's imposition of sentence under an
enhancement for repeat offenders.
C. Smith, State Appellate Defender, and Nan Jennisch,
Assistant Appellate Defender, for appellant.
J. Miller, Attorney General, Kelli Huser, Assistant Attorney
General, Michael Walton, County Attorney, and Josh Sims,
Assistant County Attorney, for appellee.
case, we must decide if the defendant was denied procedural
protections for determining his status as an habitual
offender at trial and whether he needed to preserve error by
filing a motion in arrest of judgment. On our review of a
decision by the court of appeals, we reverse the judgment and
sentences of the district court and remand for further
Background Facts and Proceedings.
Steiger was charged by two trial informations with two
separate crimes of indecent exposure. The first trial
information also charged Steiger as an habitual offender.
This charge proceeded to a bench trial. The district court
found Steiger guilty. Following the verdict, the prosecutor
informed the court he possessed three certified copies of
Steiger's three prior convictions for indecent exposure.
Defense counsel promptly responded that Steiger would
stipulate to two of the prior convictions. The court
acknowledged the stipulation without further inquiry. It then
proceeded to accept Steiger's plea of guilty to the
second charge of indecent exposure. In doing so, the court
failed to address the particulars of the plea, except to ask
Steiger if it was the result of any threats or promises. The
court did not address the requirements of filing a motion in
arrest of judgment to challenge deficiencies in the plea
was subsequently sentenced in both cases. The court imposed a
ten-year sentence of incarceration for the charge associated
with the enhancement and imposed a one-year sentence on the
other charge of indecent exposure.
appealed. On appeal, he claimed the district court erred in
accepting the stipulation relating to the prior convictions
by failing to engage in a colloquy to determine if his
acknowledgement was voluntarily and intelligently made. He
also claimed the plea of guilty to the second charge of
indecent exposure was not knowingly and voluntarily made and
the district court failed to conduct a meaningful colloquy.
Steiger further claimed he was not informed of the
requirement to file a motion in arrest of judgment to
challenge any deficiencies in the plea of guilty.
State acknowledged the plea colloquy was insufficient and the
case needed to be remanded for a new guilty-plea hearing.
However, it claimed the stipulation concerning the prior
convictions was sufficient. It further claimed Steiger failed
to preserve error for appeal by challenging the stipulation
in district court.
transferred the case to the court of appeals. The court of
appeals found Steiger failed to preserve error on his claim
that the stipulation concerning the prior convictions was
deficient. The court of appeals held Steiger was required to
challenge the sufficiency of the proceedings either by filing
a motion in arrest of judgment or by another means. Steiger
sought, and we granted, further review.