State of Iowa v. Jay E. Denton, 16-1070

Jay E. Denton pled guilty to third-degree theft pursuant to a plea agreement; the State had agreed to recommend a suspended sentence if restitution was paid before sentencing.
Denton failed to pay restitution and requested a continuance at sentencing; the court denied the continuance and proceeded to hearing three months after plea.
The State recommended 240 days in jail with none suspended; Denton agreed to 240 days but asked the court to suspend the sentence.
The district court imposed 240 days with all but 120 days suspended, assessed a fine (suspended), ordered restitution obligations and a mental-health evaluation, and found Denton indigent for attorney fees.
The court had received and considered an informal presentence investigation (PSI) from the judicial district department of correctional services summarizing Denton’s extensive criminal history and personal circumstances.
Denton appealed, arguing: (1) the court failed to consider essential sentencing factors (abuse of discretion); (2) the court improperly ordered/relied on an informal PSI; and (3) counsel was ineffective for failing to object to use of the informal PSI.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was an abuse of discretion for failing to consider minimum factors	State: sentencing was within discretion and supported by record	Denton: court gave only a terse explanation and failed to consider required factors	Court: no abuse; terse statement plus record sufficed to show consideration
Whether the court erred by ordering/considering an informal PSI	State: court may order/consider information from DOC under §901.2	Denton: use of an informal PSI was improper/illegal	Court: no error; informal PSI was permissible and sentencing rules allow such information
Whether counsel was ineffective for not objecting to use of informal PSI	State: no prejudicial error; objection would not have changed outcome	Denton: counsel should have objected to illegal PSI use	Court: counsel not ineffective—no merit to an objection and record adequate for review
Whether sentence exceeded statutory limits or required reversal	State: sentence within statutory limits and appropriate	Denton: sought reversal or modification	Court: sentence within limits; affirmed (no relief)

State v. Valin, 724 N.W.2d 440 (Iowa 2006) (standard for appellate review of sentencing errors)
State v. Neary, 470 N.W.2d 27 (Iowa 1991) (abuse-of-discretion standard for sentences within statutory limits)
State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (de novo review of ineffective-assistance-of-counsel claims)
State v. Hopkins, 860 N.W.2d 550 (Iowa 2015) (presumption in favor of trial court sentencing decisions)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (succinct reasons can be sufficient when record supports them)
State v. Buck, 510 N.W.2d 850 (Iowa 1994) (when record is adequate, ineffective-assistance claims may be decided on direct appeal)