State of Iowa v. Joshua David Johnson, 16-0870

Joshua Johnson, charged with third-degree sexual abuse for intercourse with a 15-year-old he believed was 18.
While case pending, Johnson married his girlfriend and lived with her two-year-old daughter, violating pretrial release conditions.
Johnson pled guilty; court deferred judgment and placed him on three years’ probation with conditions limiting contact with minors.
Johnson filed a pro se motion to terminate probation, arguing the minor-contact restriction was arbitrary given his lack of sexual interest in minors; the court denied it.
Johnson repeatedly violated probation (living with the child, terminating mental-health counseling, missing curfew/treatment, quitting job without approval, failing to report contacts, lying to his officer).
The district court revoked probation, imposed a ten-year deferred judgment sentence; the appeal followed challenging the reasonableness of probation conditions.

Issue	State's Argument	Johnson's Argument	Held
Whether probation condition limiting contact with minors reasonably relates to rehabilitation/community protection	Condition promotes community protection/rehabilitation and is justified by circumstances	Condition is arbitrary, not reasonably related to his rehabilitation or the crime	Probation language problematic in isolation, but treatment contract allows incidental contact; upheld insofar as violations involved non-incidental contact (living with a child)
Whether the probation condition banning contact with minors is unreasonably broad	Condition appropriately protects against future risk	Condition is excessively harsh and like Lathrop’s overbroad prohibition	Court recognized Lathrop concern but distinguished facts; living with a child violates even a narrower ban
Whether alleged violations proved by preponderance of evidence to support revocation	Multiple violations proven support revocation	Contended some grounds challenged; sought relief earlier	Court found sufficient credible violations beyond the minor-contact issue; revocation affirmed
Whether any single defective probation term mandates reversal	State argued other proven violations independently justify revocation	Johnson argued defective term required reversal of revocation	Court applied Farmer: other valid grounds adequately support revocation; judgment affirmed

State v. Valin, 724 N.W.2d 440 (Iowa 2006) (standard for reviewing probation conditions and abuse of discretion)
State v. Lathrop, 781 N.W.2d 288 (Iowa 2010) (probation condition banning all unsanctioned contact with minors held unnecessarily excessive)
State v. Hall, 740 N.W.2d 200 (Iowa Ct. App. 2007) (upheld a restriction that excepted incidental public contact with minors)
State v. Farmer, 234 N.W.2d 89 (Iowa 1975) (other independent grounds can support probation revocation)