Background
Rueben Lee Hickman pleaded guilty in Marshall County District Court to third-degree harassment, a simple misdemeanor. He appealed, contending that the district court denied him due process by accepting his plea without finding, by a preponderance of the evidence, that he was competent to stand trial.
Iowa law did not give Hickman a direct right to appeal a guilty plea to a simple misdemeanor. The Iowa Supreme Court treated his notice of appeal and brief as an application for discretionary review and transferred the matter to the court of appeals. The State argued that the appeal was also untimely, but the court did not decide that issue.
The Court’s Holding
The Iowa Court of Appeals declined to grant discretionary review and dismissed the appeal for lack of jurisdiction. Discretionary review may be granted when substantial justice has not been accorded the applicant, but the court concluded that Hickman had received substantial justice.
Nothing in Hickman’s appellate brief or the record identified an actual deficiency in the plea proceeding. The court also noted that it had recently rejected the same competency-based claim concerning Hickman’s guilty pleas to different charges, after finding that the competency-hearing transcript refuted the claim.
Key Takeaways
- A defendant has no direct right to appeal a guilty plea to a simple misdemeanor under Iowa Code section 814.6(1)(a)(3).
- The appellate court may deny discretionary review when the record shows substantial justice was accorded.
- The court did not reach the State’s argument that Hickman’s appeal was untimely.
Why It Matters
The decision underscores that a defendant challenging a simple-misdemeanor guilty plea must first obtain discretionary review and must show a meaningful reason to invoke that review. A competency allegation unsupported by the plea record—and contradicted by a prior competency ruling involving the same defendant—did not warrant review here.