State of Iowa v. Eric Devon Brown

MCDONALD, Judge.

*183 Eric Brown pleaded guilty to burglary in the third degree, in violation of Iowa Code sections 713.1 and 713.6A (2017). In this direct appeal, he contends his guilty plea lacked a factual basis, the prosecutor breached the plea agreement, and the prosecutor had a disqualifying conflict of interest.

I

Brown's first and second claims are presented as claims of ineffective assistance of counsel. Because a claim of ineffective assistance arises out of the constitutional guarantee to have the assistance of counsel for one's defense, our review is de novo. See Everett v. State , 789…