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STATE of Iowa, Plaintiff-Appellee, v. Matthew David DAUGHARTHY, Defendant-Appellant.
Matthew Daugharthy appeals after pleading guilty to driving while barred. Under Iowa Code section 814.6(1)(a)(3) (2019), there is no right of appeal “from ․ [a] conviction where the defendant has pled guilty.” There is an exception for cases in which “the defendant establishes good cause.” Iowa Code § 814.6(1)(a)(3). Daugharthy argues he has established “good cause” by claiming his plea counsel provided ineffective assistance. We disagree. “ ‘[G]ood cause’ in section 814.6 means a ‘legally sufficient reason.’ ” State v. Treptow, 960 N.W.2d 98, 109 (Iowa 2021) (citation omitted). “By definition, a legally sufficient reason is a reason that would allow a court to provide some relief.” Id. But Iowa Code section 814.7 prohibits us from deciding ineffective-assistance claims on direct appeal. Id. Put another way: Daugharthy's claim of ineffective assistance does not allow us to provide him with relief. So, by definition, his claim cannot constitute “good cause.”
Because Daugharthy has not “establishe[d] good cause,” we may not consider his claim. Iowa Code § 814.6(1)(a)(3). We must dismiss his appeal.
APPEAL DISMISSED.
MAY, Judge.
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Docket No: No. 19-1333
Decided: August 18, 2021
Court: Court of Appeals of Iowa.
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FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
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