State of Iowa v. Jeffry Robert Jensen, 16-2146

Defendant Jeffry Jensen pleaded guilty to multiple offenses and received indeterminate prison terms; the district court imposed a nine-year aggregate sentence to run consecutively.
On first appeal the Iowa Court of Appeals remanded for resentencing after the Iowa Supreme Court’s decision in State v. Hill required district courts to state specific reasons for imposing consecutive sentences.
The remand was limited to deciding whether sentences should run concurrently or consecutively and to provide reasons for that decision.
At resentencing the district court again imposed consecutive sentences and expressly articulated reasons tied to rehabilitation, public protection, review of facts, and the continuing nature and chronology of Jensen’s criminal activity.
Jensen appealed again, arguing ineffective assistance for failure to object to the court’s rejection of plea agreements, that the court should have followed plea agreements, and that the court failed to state adequate reasons for consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective at original sentencing for not objecting to rejection of plea agreements	State: prior issues are resolved and not revisited	Jensen: counsel should have objected to court rejecting plea offers	Court: Declined to revisit; law-of-the-case bars relitigation of issues decided in prior appeal
Whether district court erred by not following plea agreements at resentencing	State: Pleas were not contingent; court was not bound and remand limited	Jensen: Court should have honored plea terms	Court: Plea agreements and plea colloquy showed sentencing was open; court not bound and lacked authority on remand to revisit plea terms
Whether resentencing court failed to state adequate reasons for imposing consecutive sentences	State: Court provided targeted reasons satisfying Hill	Jensen: Reasons were insufficient under Hill	Court: Reasons were adequate—focused on rehabilitation, public protection, facts, continuing criminality and chronology; no abuse of discretion
Whether resentencing exceeded scope of remand	State: Remand limited; court complied	Jensen: Implied challenge that court should have applied plea concessions	Court: Remand limited to consecutive vs concurrent and reasons; court stayed within scope

State v. Hill, 878 N.W.2d 269 (Iowa 2016) (district courts must state specific reasons when imposing consecutive terms)
State v. Pearson, 876 N.W.2d 200 (Iowa 2016) (on remand the district court is limited to the specific action authorized by the appellate opinion)
State v. Ragland, 812 N.W.2d 654 (Iowa 2012) (law-of-the-case doctrine binds parties and courts to earlier appellate rulings)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sentences within statutory limits carry strong presumption of correctness; review for abuse of discretion)
State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (reasons for consecutive sentences need not be detailed but must provide at least a cursory explanation)