from the Iowa District Court for Linn County, Casey D. Jones,
District Associate Judge.
appeals his conviction and sentence for escape due to
ineffective assistance of counsel.
J. Goldensoph, Cedar Rapids, for appellant.
J. Miller, Attorney General, and Thomas E. Bakke, Assistant
Attorney General, for appellee.
Considered by Danilson, C.J., and Vogel and Tabor, JJ.
Pritchett appeals his conviction and sentence for the crime
of escape. Pritchett first asserts he received ineffective
assistance of counsel because his counsel allowed him to
enter a written guilty plea. He claims that had he appeared
for a plea hearing, on the record, he would have been
informed his plea may impact his probationary status on his
prior conviction. He also claims his counsel was ineffective
by allowing him to request immediate sentencing, thereby
limiting his ability to "consider his options." We
find he has not proved his ineffective-assistance-of-counsel
claims, and therefore we affirm.
Background Facts and Proceedings
was committed to a residential center following an October
11, 2017 conviction of possession with intent to deliver a
controlled substance. On December 1, he left the residential
center and failed to return. On January 16, 2018, he was
charged with escape in violation of Iowa Code section
719.4(2) (2017). On January 29, he entered into a written
guilty plea and waived his rights to appear in open court, to
have a record of the proceedings, to delay sentencing, and to
be present at sentencing. On January 30, the court accepted
the plea and imposed a sentence of a $315 fine plus
applicable surcharges and costs. He appeals.
Standard of Review
our review of a challenge to the entry of a guilty plea is
for correction of errors at law. However, when the challenge
arises in the context of an ineffective-assistance claim, our
standard of review is de novo." State v. Tate,
710 N.W.2d 237, 239 (Iowa 2006) (internal citations omitted).
Assistance of Counsel
ineffective-assistance-of-counsel claim, the defendant must
show counsel failed to perform an essential duty and such
failure resulted in prejudice. State v. Straw, 709
N.W.2d 128, 133 (Iowa 2006) (citing Strickland v.
Washington, 466 U.S. 668, 687-88 (1984)).
Entry of Plea ...