State of Iowa v. Justin Todd Brown, 16-0897

In Dec. 2014 Brown pled guilty to multiple offenses; judgment was deferred on a misdemeanor marijuana-possession count while judgments were entered (and suspended) on other counts to run consecutively.
In Sept. 2015 Brown pled guilty to a new felony (possession with intent to deliver); he was given a suspended sentence and placed on probation at a residential facility.
Brown violated probation in late 2015 by missing assignments, failing to return, and using marijuana; he stipulated to the violations in Jan. 2016.
At the Apr. 20, 2016 dispositional hearing the court revoked Brown’s probation and also revoked the earlier deferred judgment on the misdemeanor possession count.
The court adopted the State’s proposal of a 180-day jail term for the possession count and ordered that 180-day term to run consecutively to Brown’s other suspended sentences, but the court did not state on the record any reasons for selecting 180 days or for ordering it consecutive.
On appeal the court affirmed the conviction but vacated the 180-day sentence and remanded for resentencing because the sentencing court failed to comply with Iowa R. Crim. P. 2.23(3)(d) and State v. Hill.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing court stated reasons for imposing a 180-day sentence after revoking a deferred judgment	State: the court’s general reasons for revocation and prior sentencing rationale support the 180-day term	Brown: the court failed to state any reasons specific to imposing 180 days as required by rule/Hill	Court: Reversed — court did not comply with rule 2.23(3)(d) or Hill; sentence vacated and remanded for resentencing
Whether the court adequately stated reasons for ordering the 180-day term to run consecutively to other sentences	State: reasons for consecutive terms from the 2014 order apply by extension	Brown: the 2014 reasons applied only to suspended sentences, not the deferred judgment; insufficient for consecutive imposition now	Court: Reversed — prior checklist reasons did not support imposing a consecutive term on the formerly deferred count; remand required

State v. Hill, 878 N.W.2d 269 (Iowa 2016) (courts must state specific reasons on the record for chosen sentence and for imposing consecutive terms)
State v. Lillibridge, 519 N.W.2d 82 (Iowa 1994) (sentencing rules apply when judgment is entered after revocation of deferred judgment)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (generic explanations for revocation are insufficient to satisfy rule 2.23(3)(d))
State v. Thompson, 856 N.W.2d 915 (Iowa 2014) (appellate review standard for sentencing errors and procedural defects)