State of Iowa v. Christopher Ryan Covel, 925 N.W.2d 183

In 2012, 14-year-old Christopher Covel babysat his one-year-old sister, B.C.; she died of peritonitis from a rectal perforation caused by digital penetration. Covel admitted the abuse.
Covel pled guilty in 2013 to second-degree sexual abuse (class B felony); as a youthful offender the district court deferred judgment and placed him on probation with juvenile supervision, later sentenced as an adult with a five-year deferred judgment and probation in 2015.
Covel entered a residential sex-offender treatment program in 2016 but incurred 21 rule violations over 479 days and was discharged in 2017 for possession of 21 pornographic magazines before completing treatment.
The State petitioned to revoke probation; after two revocation hearings and an updated presentence investigation, the district court revoked the deferred judgment/probation and imposed the 25-year prison sentence that would have been available absent the deferred judgment (no mandatory minimum applied).
At sentencing the court ordered restitution (costs, fees, attorney fees) and found Covel had the reasonable ability to pay, but the court had not determined the total restitution amount before making that finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion revoking deferred judgment and probation	State: court properly revoked based on violations and risk of reoffense	Covel: court failed to recognize his capacity for reform and should have continued treatment/probation	Affirmed — revocation not an abuse of discretion; sufficient evidence and process supported revocation and imposition of the original sentence
Whether restitution order validly found reasonable ability to pay without knowing total amount	State: restitution and finding appropriate	Covel: court erred by finding ability to pay without total amount and required inquiry	Reversed in part — restitution vacated and remanded for resentencing consistent with Albright; court must have all items before assessing ability to pay

State v. Rogers, 251 N.W.2d 239 (Iowa 1977) (standard for overturning probation revocation)
State v. Thompson, 856 N.W.2d 915 (Iowa 2014) (abuse-of-discretion definition)
State v. Gordon, 921 N.W.2d 19 (Iowa 2018) (grounds for finding discretion untenable)
State v. Klawonn, 688 N.W.2d 271 (Iowa 2004) (standard of review for restitution orders)
State v. Bonstetter, 637 N.W.2d 161 (Iowa 2001) (reversal when findings lack substantial evidence)
State v. Darrin, 325 N.W.2d 110 (Iowa 1982) (probation revocation requires more than simple reevaluation)
Patterson v. State, 294 N.W.2d 683 (Iowa 1980) (two-step analysis for revocation: violation then disposition)
Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (due process principles for revocation proceedings)