State of Iowa v. James M. Heginger, 20-1657

James Heginger pleaded guilty to one count of assault with intent to commit sexual abuse and one count of prostitution.
At sentencing the district court imposed concurrent prison terms and ordered Heginger to "comply with the sex offender registration requirements of Iowa Code Chapter 692A for a term of life."
Heginger timely appealed, arguing the court lacked authority to order lifetime registration and that doing so violated separation of powers.
The State argued the court lacked jurisdiction to hear a direct appeal from a guilty plea unless defendant showed "good cause."
The court noted precedent holding the length of sex-offender registration is an administrative determination committed to the Iowa Department of Public Safety, and that district courts should not determine registration duration at sentencing.
The court vacated the portion of the sentence requiring registration "for a term of life," and affirmed the remainder of the sentence; the State conceded the district court lacked authority to order lifetime registration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to hear direct appeal after guilty plea	State: defendant must show good cause under Iowa Code § 814.6 to appeal a sentence entered on a guilty plea	Heginger: he challenges an illegal sentence (registration duration), not the plea, so good cause exists	Court: Good cause shown because the challenge is to the sentence, so appeal may proceed
Authority to impose duration of sex-offender registration	State: conceded district court lacked authority to impose lifetime registration	Heginger: district court exceeded statutory authority and violated separation of powers by ordering lifetime registration	Court: District court erred; registration-duration determinations are administrative (DPS). Vacated the words "for a term of life," affirmed remainder of sentence

State v. Damme, 944 N.W.2d 98 (Iowa 2020) (defendant bears burden to show good cause to directly appeal after guilty plea)
State v. Tucker, 959 N.W.2d 140 (Iowa 2021) (sentencing errors arise after plea and can support good-cause appeals)
Barker v. Iowa Dep’t of Pub. Safety, 922 N.W.2d 581 (Iowa 2019) (length of sex-offender registration is an administrative decision for DPS)
State v. Bullock, 638 N.W.2d 728 (Iowa 2002) (district courts should not determine registration responsibility/duration at sentencing)
State v. Goodson, 958 N.W.2d 791 (Iowa 2021) (sentencing orders specifying registration duration are illegal)
State v. Keutla, 798 N.W.2d 731 (Iowa 2011) (illegal but severable portions of a sentence may be vacated without disturbing remainder)