State of Iowa v. Dyan Marie Lee-Brown, 15-1534

Dyan Lee-Brown was convicted of possession of marijuana under Iowa Code § 124.401(5). She does not contest the possession conviction.
Lee-Brown has two prior chapter 124 convictions: possession of methamphetamine (§ 124.401(5)) and possession of drug paraphernalia (§ 124.414).
The sentencing question: whether the current marijuana possession conviction is subject to enhancement as a second or third offense under § 124.401(5) given prior chapter 124 convictions.
Lee-Brown argued enhancement should apply only for prior convictions of the same subsection (possession of a controlled substance), not any prior chapter 124 offenses.
The State and the district court treated the statutory language—“two or more times of violating this chapter”—as encompassing all prior chapter 124 convictions, making Lee-Brown a third offender and subjecting her to the harsher penalty.
The court of appeals reviewed statutory interpretation principles, legislative amendments (notably 2000 changes), and whether the literal reading produced absurd results; it affirmed the enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prior conviction under any provision of chapter 124 can count to elevate a § 124.401(5) possession charge to a "third offender" felony	Lee‑Brown: only prior convictions of the same subsection (possession of a controlled substance/marijuana) should count for enhancement	State: the statute’s phrase "violating this chapter" unambiguously includes any chapter 124 convictions (including paraphernalia)	Court: affirmed—language unambiguous; prior chapter 124 convictions count, so Lee‑Brown is a third offender
Whether the literal statutory reading produces an absurd result warranting judicial departure	Lee‑Brown: allowing simple misdemeanors (paraphernalia) to enhance to felony is absurd and contrary to legislative intent	State: literal text is controlling; no absurdity that compels rewriting statute	Court: result is unusual but not legally "absurd"; will not rewrite statute; policy concerns for legislature

Rhoades v. State, 880 N.W.2d 431 (Iowa 2016) (statutory interpretation principles and ambiguity standard)
State v. Albrecht, 657 N.W.2d 474 (Iowa 2003) (start interpretation with statutory text)
State v. Nicoletto, 862 N.W.2d 621 (Iowa 2015) (statutory construction rules)
State v. Freeman, 705 N.W.2d 286 (Iowa 2005) (discussing enhanced penalties in § 124.401(5))
State v. Cortez, 617 N.W.2d 1 (Iowa 2000) (distinguishing stricter and lenient penalty tracks in § 124.401(5))
State v. Rankin, 666 N.W.2d 608 (Iowa 2003) (lenient track applies only where prior and current convictions are marijuana possession)
State v. Walden, 870 N.W.2d 842 (Iowa 2015) (absurd-results doctrine is used sparingly)
State v. Rohm, 609 N.W.2d 504 (Iowa 2000) (construe statute in context of purpose and design)