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Case No. 19-1506

State of Iowa
Randy Allen Crawford

Randy Crawford seeks further review after the court of appeals affirmed his conviction for failure to affix a drug tax stamp. Crawford argued his counsel was ineffective in failing to properly challenge the sufficiency of the evidence. The court of appeals held section Iowa Code section 814.7 prevented the court from deciding Crawford’s claim of ineffective assistance on direct appeal and that Crawford had not proven section 814.7 is unconstitutional. Crawford requests the supreme court reexamine its recent holding in State v. Treptow—where the court upheld various constitutional challenges to section 814.7—and its application to jury verdicts.



State of Iowa


Randy Allen Crawford

Attorney for the Resister

Timothy M. Hau

Attorney for the Applicant

Theresa R. Wilson

Supreme Court

Oral Argument Schedule


Dec 14, 2021 1:30 PM


Supreme Court Opinion

Opinion Number:
Date Published:
Mar 18, 2022
Date Amended:
May 31, 2022

Court of Appeals

Court of Appeals Opinion

Opinion Number:
Date Published:
Aug 04, 2021

            Appeal from the Iowa District Court for Scott County, Henry W. Latham II, Judge.  AFFIRMED.  Considered by Doyle, P.J., and Tabor and Greer, JJ.  Opinion by Greer, J. (4 pages)

            Randy Crawford brings an ineffective-assistance-of-counsel claim on direct appeal.  Recognizing that Iowa Code section 814.7 (Supp. 2019) prevents us from deciding claims of ineffective assistance on direct appeal, Crawford argues the statute violates separation-of-powers doctrine, equal protection, and his right to due process.  Lastly, if we cannot consider his claim under the framework of ineffective assistance, Crawford asks us to adopt plain error review.  OPINION HOLDS: Because section 814.7 prevents us from deciding Crawford’s claim of ineffective assistance on direct appeal and he has not proved section 814.7 is unconstitutional, we affirm. 

Other Information

Date Further Review is Granted:
Sep 28, 2021
Date Retained:
Sep 28, 2021
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