State of Iowa v. Cody Allen Standlee, 16-1916

Defendant Cody Standlee entered Alford pleas to two counts of second-degree sexual abuse and one count of indecent exposure.
District court sentenced him to up to 25 years on each sexual-abuse count, ordered the two sexual-abuse sentences to run consecutively, and set the one-year indecent-exposure sentence to run concurrently.
The court later entered a five-year no-contact order that named the two child victims and "all children under the age of eighteen years" as protected persons.
On appeal Standlee challenged (1) the adequacy of the court’s stated reasons for imposing consecutive sentences and (2) the statutory authority to include "all children under eighteen" in the no-contact order.
The State conceded the no-contact order overbroadly named all children; the court treated the appeal as a certiorari action for that claim and granted the writ.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court gave adequate on-the-record reasons for consecutive sentences	The State: the court’s terse reasons are sufficient under Rule 2.23(3)(d) and precedent	Standlee: the court failed to state adequate reasons for consecutive sentences	Court: The brief, explicit statement describing the offenses’ separate and serious nature and compliance incentive was sufficient; sentence affirmed
Whether the court exceeded statutory authority by naming "all children under eighteen" in the no-contact order	The State: initially argued procedural bar to direct appeal but conceded statutory overbreadth	Standlee: the no-contact order exceeded statutory limits in Iowa Code § 664A.1(1)	Court: No-contact order vacated insofar as it includes "all children under eighteen"; remanded for corrected order and specific naming of authorized protected persons

State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (standard of review for sentencing: correction of errors at law and abuse of discretion)
State v. Hill, 878 N.W.2d 269 (Iowa 2016) (sentencing courts must state reasons for consecutive sentences but may be brief)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (a terse, succinct statement can suffice if it permits review of sentencing discretion)
Crowell v. State Pub. Def., 845 N.W.2d 676 (Iowa 2014) (appellate rules allow treating an appeal as a certiorari action when appropriate)
State v. Hall, 740 N.W.2d 200 (Iowa Ct. App. 2007) (courts must comply with statutory limits when issuing no-contact orders)
North Carolina v. Alford, 400 U.S. 25 (1970) (defendant may plead guilty while maintaining innocence if plea is voluntary and intelligent)