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Case No. 18-0839

State of Iowa
Erin Macke

Defendant appealed the district court’s judgment of conviction and sentence entered on four counts of child endangerment following defendant’s entry of an Alford guilty plea. See North Carolina v. Alford, 400 U.S. 25 (1970). Defendant contended the State’s sentencing recommendation breached the parties’ plea agreement and her trial counsel was ineffective in failing to object to the breach. She also requested the adoption of the plain error doctrine in Iowa. The court of appeals affirmed, preserving the ineffective assistance claim for postconviction relief. Defendant seeks further review.

Trial Court Case No.:


State of Iowa


Erin Macke

Attorney for the Appellee

Thomas J. Ogden, Assistant Attorney General

Attorney for the Appellant

Angela L. Campbell

Supreme Court

Oral Argument Schedule


Aug 08, 2019 9:00 AM


Supreme Court Opinion

Opinion Number:
Date Published:
Sep 13, 2019
Date Amended:
Dec 06, 2019

Court of Appeals

Court of Appeals Opinion

Opinion Number:
Date Published:
Mar 20, 2019

            Appeal from the Iowa District Court for Polk County, Carol S. Egly, District Associate Judge.  AFFIRMED.  Considered by Vaitheswaran, P.J., and Doyle and Mullins, JJ.  Opinion by Doyle, J.  (10 pages)

            Erin Macke appeals the judgement and sentence entered following her plea to four counts of child endangerment.  OPINION HOLDS: Because the record is insufficient to determine Macke’s ineffective-assistance-of-counsel claim on the merits, we affirm her convictions and preserve the issue of ineffective assistance of counsel for postconviction-relief proceedings.  We decline to adopt the plain-error doctrine. 

Other Information

Date Further Review is Granted:
Jun 18, 2019

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