State of Iowa v. Hannah Leeann Johnston, 24-0302

Hannah Johnston was arrested shortly after turning 18 for first-offense marijuana possession and received a deferred judgment in October 2022.
Over the next year, four probation violation reports were filed against Johnston, including arrests for operating while intoxicated and repeated positive drug tests for methamphetamine.
Johnston admitted to several probation violations, resulting in increased probation conditions, including both outpatient and inpatient treatment requirements.
In December 2023, she was charged with new offenses (possession of drug paraphernalia and fentanyl) and failed another drug test.
After a hearing in February 2024, where her compliance and new charges were discussed, the court revoked her deferred judgment and sentenced her to 180 days in jail.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court improperly considered unproven charges when sentencing Johnston after probation revocation	Johnston: The court considered unproven criminal charges in Polk County in sentencing.	State: The majority of the hearing and the sentencing did not focus on unproven charges, and the court did not indicate reliance on them.	The court did not abuse its discretion; no affirmative showing it relied on unproven charges. Sentence affirmed.

State v. Gordon, 921 N.W.2d 19 (Iowa 2018) (court cannot consider unproven or unprosecuted offenses unless admitted by the defendant or proven by facts)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sentencing reviewed for abuse of discretion)
State v. Matheson, 684 N.W.2d 243 (Iowa 2004) (court should clarify that unproven charges were not considered at sentencing)
State v. Sailer, 587 N.W.2d 756 (Iowa 1998) (trust in district courts to disregard improper evidence at sentencing)