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STATE v. DAUGHARTHY (2021)

Court of Appeals of Iowa.2021-08-18No. No. 19-1333

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Opinion

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: Daugharthys 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.