State of Iowa v. Bryce Lamont Meeks, 16-1611

Defendant Bryce Meeks was charged with driving while barred as a habitual offender (aggravated misdemeanor) and submitted a written guilty plea.
Less than an hour after the first plea form, Meeks submitted a second nearly identical plea form that checked: “I waive my right to have a verbatim record of these proceedings.”
The plea hearing and the subsequent sentencing hearing were not reported. A presentence investigation report (PSI) was reviewed at sentencing, Meeks spoke in mitigation, and the court sentenced him to up to two years’ incarceration and a suspended fine.
On appeal Meeks argued the district court erred by either failing to provide a verbatim record at sentencing or failing to state on the record that he waived such a record, creating a procedural defect requiring resentencing.
The court examined the plea form (which covered plea and sentencing rights, allocution, and PSI) and concluded Meeks expressly waived the verbatim-record requirement for both proceedings; the court’s acceptance of the plea amounted to acceptance of the waiver.
The Court of Appeals found no procedural error or abuse of discretion and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by not providing a verbatim record at sentencing or by failing to state Meeks waived such a record	Meeks’s written plea expressly waived a verbatim record of “these proceedings,” which the court accepted; waiver covers both plea and sentencing, so no error	The waiver was unclear as to whether it applied to sentencing; the court failed to state on the record that Meeks waived the verbatim record at sentencing	Waiver was valid and unambiguous; plea form’s reference to “these proceedings” encompassed plea and sentencing; acceptance of plea constituted acceptance of waiver; sentence affirmed

State v. Craig, 562 N.W.2d 633 (Iowa 1997) (standard for abuse of discretion in sentencing review)
State v. Millsap, 547 N.W.2d 8 (Iowa Ct. App. 1996) (discussing appellate review standards and sentencing procedure)