State of Iowa v. Rueben Lee Hickman

IN THE COURT OF APPEALS OF IOWA
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No. 25-0188
Filed April 1, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Rueben Lee Hickman,
Defendant–Appellant.
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Appeal from the Iowa District Court for Marshall County,
The Honorable Kathryn E. Austin, Judge.
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AFFIRMED
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Gary Dickey of Dickey, Campbell, & Sahag Law Firm, PLC, Des Moines,
attorney for appellant.

Brenna Bird, Attorney General, and Katherine Wenman, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Tabor, C.J., Langholz, J., and Vogel, S.J.
Opinion by Langholz, J.

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LANGHOLZ, Judge.

Rueben Hickman appeals his convictions after pleading guilty to
possession of a controlled substance, third offense, and operating while
intoxicated, first offense. He argues that the district court violated his
constitutional right to due process by accepting his guilty pleas without first
finding that his competency was restored after the proceedings had been
suspended because of his incompetence. See State v. Brown, 16 N.W.3d 288,
292 (Iowa 2025); Iowa Code §§ 812.3–.6 (2023). Hickman acknowledges that
the court scheduled a hearing on his competency after receiving a report from
an Iowa Department of Corrections psychiatrist concluding that he was
competent to stand trial. But he asserts “[i]t is unclear whether that hearing
occurred” and notes that no order was filed after the hearing. He thus
concludes that “the court never found by a preponderance of the evidence
that Hickman had been restored to competency.”

The transcript of the competency hearing refutes Hickman’s claim.1
After hearing from both parties, the court found “based on the reports of the
physician, that Mr. Hickman is competent to stand trial, that his competency
has been restored.” So these proceedings were reinstated. And Hickman filed
a written guilty plea to one offense three days later and to the other a couple
weeks after that. We thus reject Hickman’s claim that the court accepted his
guilty pleas before finding that his competency was restored. Hickman does
not argue that the court erred in finding that he was competent or make any
other challenge to his convictions. We thus affirm.

AFFIRMED.

After Hickman filed his brief, the supreme court granted the State leave to file a
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supplemental combined certificate to order the recently discovered hearing transcript.

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