State of Iowa v. Amy Lois Rasmussen, 7 N.W.3d 357

Amy Rasmussen physically confronted three women outside Boone City Hall after a city council forum, resulting in injuries.
Rasmussen entered an Alford plea to two counts of assault causing bodily injury (against Victims 1 and 2); the State dismissed a related simple misdemeanor charge involving Victim 3.
The district court sentenced Rasmussen to consecutive one-year terms (two years total) and imposed five-year no-contact orders for all three victims, including Victim 3 (whose charge was dismissed).
Rasmussen challenged her sentence on grounds that the court considered improper factors, and claimed the no-contact order for Victim 3 (from the dismissed case) was illegal.
The Court of Appeals affirmed the sentence and all no-contact orders. The Supreme Court of Iowa reviewed further.
The Supreme Court affirmed the conviction and sentences for Victims 1 and 2, but held the no-contact order for Victim 3 in the dismissed case was void and remanded for further hearing on whether such an order could be supported in the current case.

Issue	Rasmussen's Argument	State's Argument	Held
Whether district court considered improper factors in sentencing	Court considered victim-impact statement from Victim 3 who was not legally a "victim"; didn't give enough weight to mitigating factors	Sentencing was individualized, proper factors used	No abuse of discretion; district court properly considered factors
Whether district court could enter a no-contact order for dismissed misdemeanor case (Victim 3)	No-contact order for Victim 3 was illegal without a conviction	Might still be authorized due to the circumstances	Order in dismissed case was void; remanded for hearing on no-contact order in this case
Whether the court should extend no-contact order to all three victims	No, especially for Victim 3 since her charge was dismissed	Yes, due to shared facts underlying all counts	Remand to determine whether Victim 3 qualifies as a "victim" under statute
Whether plea agreement/wavier can validate an otherwise illegal sentence	Defendant did not contest at sentencing, so should stand	Illegal sentences void regardless of agreement	Illegal sentences cannot be saved by contract or waiver

State v. Damme, 944 N.W.2d 98 (Iowa 2020) (good cause to appeal a sentence after guilty plea)
State v. Wiederien, 709 N.W.2d 538 (Iowa 2006) (no authority for no-contact order absent conviction)
State v. Sailer, 587 N.W.2d 756 (Iowa 1998) (presumption court only considers proper sentencing factors)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sentencing courts must consider multiple statutory factors)
State v. Ohnmacht, 342 N.W.2d 838 (Iowa 1983) (illegal sentences not subject to waiver or agreement)