In State v. Finney, a panel of this court found “Finney received ineffective assistance because defense counsel permitted him to plead guilty to attempted murder when there was not a sufficient factual basis in the record.” No. 12–0010, 2012 WL 3027113, at *2 (Iowa Ct.App. July 25, 2012). Specifically, it found Finney's lone statement during the plea colloquy that he shot the victim was inadequate by itself to factually support the guilty plea.

The parties debate whether our review is limited to Buttrom's plea hearing colloquy or if we may review the entire record to determine whether a factual basis exists to support both pleas. Buttrom relies on State v. Philo, 697 N.W.2d 481, 486 (Iowa 2005), and State v. Finney, No. 12-0010, 2012 WL 3027113, at *2 (Iowa Ct. App. July 25, 2012), to contend we can look only to his statements during the plea hearing because the district court did not specify it was relying on other parts of the record to satisfy the factual bases for his guilty pleas. The State acknowledges the district court did not expressly consider the minutes of testimony in its factual-basis finding, but argues, under State v. Ortiz, 789 N.W.2d 761, 767-68 (Iowa 2010) and previous caselaw, we may review the entire record to determine whether a factual basis exists.