State of Iowa v. Anouhak Anna Keutla
2011 Iowa Sup. LEXIS 40
| Iowa | 2011Background
- Keutla pled guilty to manufacturing a controlled substance and received a deferred judgment with two years of supervised probation and a $750 civil penalty.
- She faced additional charges in Warren and Polk Counties in 2008, leading to probation violations and a decision to continue probation with increased supervision.
- In August–September 2009, after numerous violations, the district court revoked the deferred judgment, adjudicated guilt, imposed a suspended five-year prison sentence, ordered probation, fined, and ordered six months in jail for contempt.
- Keutla appealed, challenging the district court’s authority to revoke the deferred judgment and to punish contempt, and challenging the fine amount.
- The Court of Appeals vacated the contempt portion but left the revocation of the deferred judgment and the sentence intact, remanding for a fine adjustment; Keutla sought further review.
- The Iowa Supreme Court held that the district court could not simultaneously revoke the deferred judgment and punish contempt in the same proceeding, and remanded for resentencing within the authorized options of §908.11(4); the revocation and contempt findings were reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to revoke and contempts in one proceeding | Keutla: §907.3(1) and §908.11(4) allow both actions in one proceeding | Keutla: cannot exercise two separate options in one proceeding; authority limited to one of four options | Only one of four §908.11(4) options may be chosen; cannot revoke deferred judgment and punish contempt in same proceeding |
| Remedy for improper sentencing | Keutla: remand for resentencing if error occurred | Keutla: court should remand for resentencing rather than severing the contempt | Remand for resentencing within the authorized options; reverse revocation and contempt, remand for proper sentencing |
Key Cases Cited
- State v. Gonzalez, 718 N.W.2d 304 (Iowa 2006) (statutory interpretation with focus on legislative intent)
- State v. Freeman, 705 N.W.2d 286 (Iowa 2005) (corpus mentality on error correction for legal rulings)
- State Pub. Defender v. Iowa Dist. Ct., 633 N.W.2d 280 (Iowa 2001) (certiorari review of contempt orders)
- State v. Krivolavy, 258 N.W.2d 157 (Iowa 1977) (severability when improper sentence is entangled with valid sentence)
- State v. Matlock, 289 N.W.2d 625 (Iowa 1980) (remand for resentencing when illegality cannot be severed)