State of Iowa v. Chad Jay Rouse
858 N.W.2d 23
Iowa Ct. App.2014Background
- Chad Rouse pled guilty (Alford plea) to serious-injury-by-vehicle (Iowa Code §707.6A(4)) and OWI in the same proceeding.
- The State charged the serious-injury count under subsection 4 based on reckless driving (707.6A(2)(a)), not the intoxication-based means in subsection 1.
- The district court held a law-point hearing on whether it could suspend the sentence for the serious-injury conviction and concluded it lacked authority to suspend.
- The court sentenced Rouse to concurrent terms (up to 5 years for serious injury, 1 year for OWI) and Rouse appealed the suspension issue.
- The core statutory provision was §707.6A(7), which bars deferral or suspension for violations “involving the operation of a motor vehicle while intoxicated.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court had authority to suspend the sentence for serious-injury-by-vehicle under §707.6A(7) | State: §707.6A(7) bars suspension when the offense “involved” operation while intoxicated; applies here because the serious-injury offense related to OWI | Rouse: His subsection 4 conviction was based on reckless driving (no intoxication element), so §707.6A(7) shouldn’t bar suspension | Court: §707.6A(7)’s broad term “involving” covers Rouse’s offense (he was charged and pled to OWI in same proceeding); court lacked authority to suspend |
| Whether §707.6A(7) as applied violates equal protection | State: statute is constitutional; legislature may treat offenses differently based on offense nature and public safety concerns | Rouse: Disparate treatment (death-by-reckless driving can be suspended while serious-injury-by-reckless cannot) denies equal protection | Court: Rejects challenge; equal protection analysis focuses on nature of offense and Kolbet controls—no violation |
Key Cases Cited
- Wiederien v. State, 709 N.W.2d 538 (Iowa 2006) (plain-language statutory interpretation principles)
- Bruegger v. State, 773 N.W.2d 862 (Iowa 2009) (illegal sentence and preserved-error principles for sentencing and constitutional claims)
- Wade v. State, 757 N.W.2d 618 (Iowa 2008) (equal protection analysis—compare nature of offenses, not just classifications)
- Kolbet v. State, 638 N.W.2d 653 (Iowa 2001) (upholding §707.6A against equal protection challenge; distinguishes drunken driving risk)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (Alford plea explanation)