State of Iowa v. Brent Marlon Smith, 21-0069

Defendant Brent Smith convicted of second-degree burglary and stalking (violation of a protective order), both as a habitual offender; court imposed concurrent terms not to exceed 15 years each.
The State recommended a longer term; defense asked for probation, citing Smith’s drug addiction and nearly yearlong sobriety and arguing he needed mental-health/substance-abuse treatment rather than incarceration.
PSI showed an extensive criminal history dating to 1997, including ten assault convictions, a terrorism conviction, and five violations of parole/probation/work release (most recently 2019).
Facts of the instant offenses: after a temporary protective order on Dec 25, 2019, Smith entered the protected party’s home that day and then twice more violated the order two weeks later—once ambushing the victim, forcing her into the house, threatening rape and murder, and later found in the house by police.
The district court denied probation, citing public safety and Smith’s record; the court noted treatment can be provided during incarceration and relied on Smith’s history and recent conduct.
On appeal Smith argued the court abused its discretion by denying probation; the Court of Appeals reviewed for abuse of discretion and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying probation	Denial was proper: court reasonably prioritized public protection and Smith’s extensive criminal history	Probation was appropriate to allow mental-health/substance-abuse treatment instead of prison	Affirmed—no abuse of discretion; court relied on tenable grounds (danger to public, prior record)
Whether need for mental-health/substance-abuse treatment required probation	Treatment can occur in custody; public safety may outweigh treatment considerations	Smith needed community-based treatment and sobriety supported probation	Held against Smith; court permissibly gave greater weight to record of convictions and public protection; PSI undermined claim of active addiction/illness

State v. Wright, 340 N.W.2d 590 (Iowa 1983) (standard for reviewing sentencing discretion and factor balancing)
State v. Evans, 672 N.W.2d 328 (Iowa 2003) (abuse-of-discretion framework for sentencing review)
State v. Pappas, 337 N.W.2d 490 (Iowa 1983) (presumption in favor of sentencing court’s exercise of discretion)
State v. Damme, 944 N.W.2d 98 (Iowa 2020) (appellate role is not to second-guess sentencing choices but to assess reasonableness of the court’s rationale)