State of Iowa v. Clifton L. Johnson, 16-1073

Clifton L. Johnson had a lengthy criminal history, mostly misdemeanors and two prior serious-misdemeanor controlled-substance convictions (2004, 2014).
In March 2015 (FECR284624) Johnson pled guilty to felony eluding and to operating a vehicle without the owner’s consent (aggravated misdemeanor); he received concurrent five-year and two-year sentences, suspended, and was placed on two years’ probation with a residential-treatment requirement.
Johnson was later dismissed from the treatment program, a warrant was issued, and during a 2016 arrest he was found with cocaine, methamphetamine, and marijuana.
Charged in AGCR293160 with three counts of third-offense possession of a controlled substance, Johnson pled guilty to one count (class D felony) without habitual-offender enhancement; the State agreed probation in FECR284624 would be revoked and previously suspended sentences imposed.
At sentencing, the State sought consecutive sentences; the district court imposed a five-year sentence in AGCR293160 consecutive to the five-year sentence from FECR284624 (total ten years). Johnson appealed, arguing the court should have ordered concurrent sentences to maximize rehabilitation and because the offense was nonviolent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by ordering Johnson’s new five-year felony sentence to run consecutively to his previously imposed five-year sentence (resulting in 10 years total)	State: consecutive sentence permissible; court considered appropriate sentencing factors and statutory limits	Johnson: consecutive sentence thwarts rehabilitation; nonviolent offense and concurrent term would allow earlier treatment	Court affirmed: no abuse of discretion; district court reasonably considered criminal history, age, substance-abuse history, offense nature, and public protection in imposing consecutive sentences

State v. Letscher, 888 N.W.2d 880 (Iowa 2016) (standard for appellate review of sentencing)
State v. Seats, 865 N.W.2d 545 (Iowa 2015) (sentencing review deference)
State v. Hill, 878 N.W.2d 269 (Iowa 2016) (abuse-of-discretion definition in sentencing)
State v. Hopkins, 860 N.W.2d 550 (Iowa 2015) (presumption favoring trial court sentencing)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (factors district court must consider in sentencing)