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State of Iowa v. Joseph Manuel Jones
16-1723
| Iowa Ct. App. | Apr 19, 2017
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Background

  • Defendant Joseph Jones pleaded guilty to operating while intoxicated (OWI), first offense, a serious misdemeanor; a driving-while-revoked charge was dismissed per plea agreement.
  • Jones waived a record of the guilty plea and sentencing proceedings and his right of allocution.
  • The district court sentenced Jones to one year in jail with all but 90 days suspended, followed by probation, ordered payment of a $1250 fine plus surcharges/fees, and completion of the OWI first offender program.
  • The district court identified key sentencing factors on its form: nature/circumstances of the crime, public protection, Jones's criminal and substance-abuse history, rehabilitation prospects, the plea agreement, and the presentence investigation report.
  • Jones argued the court abused its discretion by failing to consider mitigating factors (custody of two children, full-time employment and employer support, successful coursework, difficult upbringing, long interval since prior OWIs, and lack of physical harm from the offense).
  • The appellate court reviewed for abuse of discretion and upheld the sentence as within statutory parameters and not clearly untenable or unreasonable.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the district court abused its discretion in sentencing Sentence was lawful, within statutory limits, and based on appropriate factors Court failed to consider significant mitigating factors (family responsibilities, employment, rehabilitation progress, minor nature of offense) Affirmed — no abuse of discretion; sentence was reasonable and court properly exercised discretion

Key Cases Cited

  • State v. Hopkins, 860 N.W.2d 550 (Iowa 2015) (standard of review and presumption of validity for sentences within statutory limits)
  • State v. Leckington, 713 N.W.2d 208 (Iowa 2006) (definition of abuse of discretion standard)
  • State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (use of sentencing forms and demonstration that court exercised discretion)
Read the full case

Case Details

Case Name: State of Iowa v. Joseph Manuel Jones
Court Name: Court of Appeals of Iowa
Date Published: Apr 19, 2017
Docket Number: 16-1723
Court Abbreviation: Iowa Ct. App.