State of Iowa v. Archaletta Latrice Young

APPEL, Justice.

In this case, we consider whether a misdemeanor conviction pursuant to a guilty plea by an incarcerated poor person who did not have the assistance of counsel, may later be used by the State as a predicate offense for application of a theft statute in which the crime is enhanced if the defendant has two prior theft offenses. The district court concluded the prior uncoun-seled misdemeanor conviction could be used as an offense to trigger enhanced punishment when the facts surrounding the prior conviction were that the defendant failed to appear; she was arrested and held in jail…