Michael Anderson v. State of Iowa
801 N.W.2d 1
| Iowa | 2011Background
- Anderson pleaded guilty by Alford plea to two counts of enticing away a minor and was sentenced to two five‑year prison terms, suspended on probation with the DCS for five years on each count.
- Probation required sex-offender treatment at a residential facility; after discharge he was placed on electronic monitoring and home supervision with daily check-ins.
- While on electronic monitoring, Anderson could work and leave for certain errands, but remained under supervision, with access to home amenities and restricted contact with minors.
- A 2006 probation violation led to revocation and reinstatement of the prison terms; Anderson sought credit for time spent under home electronic monitoring.
- The district court denied such credit; the court of appeals affirmed; the Iowa Supreme Court granted further review to resolve statutory interpretation of credit rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 907.3(3) requires credit for time under electronic monitoring | Anderson argues 907.3(3) grants credit for time served under DCS supervision. | State contends only jail-like confinement yields credit under 907.3(3). | Yes; 907.3(3) authorizes credit for time served under supervision. |
| Whether 903A.5(1) supports credit for time under home confinement | Anderson contends 903A.5(1) encompasses presentence confinement like home monitoring. | State relies on narrow reading restricting credit to jail-like facilities. | No; 903A.5(1) does not apply as to home electronic monitoring. |
| Whether the absurd results doctrine should bar credit | Argues credit would be counterintuitive but consistent with statute. | Argues applying credit yields absurd result. | The plain language controls; no absurd result warranting disregard of statute. |
Key Cases Cited
- State v. Hearn, 797 N.W.2d 577 (Iowa 2011) (statutory interpretation; strict construction in criminal statutes)
- State v. Rodenburg, 562 N.W.2d 186 (Iowa 1997) (textual interpretation; credit only for incarceration facilities)
- State v. Pickett, 671 N.W.2d 866 (Iowa 2003) (supervision under DCS can constitute supervision for credit purposes)
- Sherwin-Williams Co. v. Iowa Department of Revenue, 789 N.W.2d 417 (Iowa 2010) (absurd results doctrine discussed and narrowly applied)
- Holland v. State, 253 Iowa 1006 (Iowa 1962) (lex talionis-like admonition on reading statutes; origin of interpretive approach)