State of Iowa v. Evan Paul Headley, 926 N.W.2d 545

On July 28, 2017 Evan Headley forced his ex-girlfriend S.M. into her home, restrained her and left visible injuries; he was on probation and subject to protective orders at the time.
Headley pleaded guilty to second-degree burglary and enhanced domestic abuse assault pursuant to a plea agreement.
A presentence investigation report (PSI) included two actuarial risk instruments (Iowa Risk Revised (IRR) and DRAOR), mental-health/substance screening, and a DOC sentencing recommendation; the PSI recommended incarceration.
At sentencing the judge asked defense counsel whether they reviewed the PSI; counsel replied they had and had no corrections. The court imposed an aggregate prison term (up to 18 years) and stated restitution would be ordered if a specific amount was presented.
The sheriff later sought reimbursement for jail room-and-board and the court assessed court costs and correctional fees against Headley. Headley appealed his sentence raising multiple challenges.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Headley)	Held
Whether court abused discretion by considering actuarial risk tools in PSI	Tools are pertinent information and permissible for sentencing	Use of IRR/DRAOR is unauthorized by statute and thus improper	Court did not abuse discretion to consider the tools on their face as PSI content
Whether consideration of risk tools violated due process	N/A – State defends sentencing practice	Use of actuarial tools without notice/record violated due process; limitations/cautions were not before court	Claim not preserved; record insufficient for direct review—may be raised in postconviction relief
Whether court abused discretion by considering DOC sentencing recommendation	Recommendation is nonbinding but is pertinent information about risk/rehabilitation	DOC recommendation improperly influenced sentencing	Court did not abuse its discretion in considering the DOC recommendation
Whether restitution/costs were illegally imposed and whether ability-to-pay was considered	Court costs and correctional fees may be assessed where costs would have been incurred; restitution order appropriate if ability to pay analyzed	Ordering costs for dismissed charges and imposing fees without first determining reasonable ability to pay rendered sentence illegal/error	Assessment of costs for dismissed charges was not illegal; however restitution/costs were imposed without required ability-to-pay analysis—restitution vacated and remanded for that analysis

State v. Gordon, 921 N.W.2d 19 (Iowa 2018) (defendant must object at sentencing to preserve due-process challenge to PSI risk tools unless the record alone resolves the impropriety)
State v. Guise, 921 N.W.2d 26 (Iowa 2018) (arguments about actuarial tool limits are essentially due-process claims that must be preserved)
State v. Seats, 865 N.W.2d 545 (Iowa 2015) (abuse-of-discretion standard for sentences within statutory limits)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (societal goals of sentencing include rehabilitation and community protection)
State v. Pappas, 337 N.W.2d 490 (Iowa 1983) (sentencing judges have broad discretion to rely on information presented at sentencing)
State v. Grgurich, 253 N.W.2d 605 (Iowa 1977) (PSI recommendations are advisory and not binding on the court)
State v. Cupples, 152 N.W.2d 277 (Iowa 1967) (courts should consider nature of offense, defendant’s character and prospects for reform when sentencing)