State of Iowa v. Allen Robert Allensworth
2012 Iowa Sup. LEXIS 104
| Iowa | 2012Background
- This is an Iowa Supreme Court case reviewing earned-time credit for time spent on supervised probation before incarceration.
- Allensworth received suspended sentences and two years of probation; probation was revoked and he was reincarcerated.
- The central issue is whether earned-time credit under Iowa Code §903A.2 can accrue while the defendant is on supervised probation.
- The district court and IDOC disagree on the order of applying earned time, jail time, and probation credit to compute a tentative discharge date.
- The court ultimately holds that earned-time credit cannot accrue during probation and affirms the district court’s denial of such credit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can earned-time credit accrue during supervised probation under §903A.2? | Allensworth argues earned time should accrue prior to probation credit. | IDOC argues earned time only accrues when incarcerated. | No; earned time does not accrue during probation. |
| What is the proper sequence to apply credits (earned time, jail time, probation)? | Earned time should be applied first to reduce the sentence. | Probation credit should be applied first, then earned time. | Earned time is not available before placement; probation credit applies before earned time. |
| Does §907.3(3) probation credit allow earned-time credit for probation outside incarceration? | probation credit plus earned time should combine to reduce sentence. | Earned time cannot be earned while on probation outside custody. | No; earned-time credit is not triggered by probation outside confinement. |
Key Cases Cited
- Anderson v. State, 801 N.W.2d 1 (Iowa 2011) (probation credit authorized for time served after commitment; amendments later clarified scope)
- Kolzow v. State, 813 N.W.2d 731 (Iowa 2012) (statutory interpretation harmonizing multiple credit statutes)
- State v. Canas, 571 N.W.2d 20 (Iowa 1997) (lenity not applicable to unambiguous statutes limiting credits)
- Trecker v. State, 320 N.W.2d 594 (Iowa 1982) (original understanding of probation credits before amendments)