State of Iowa v. Kenneth Hoxsey, 20-1531

Kenneth Hoxsey pleaded guilty to third-degree burglary and, two weeks later, second-degree burglary.
The presentence investigation (PSI) recommended incarceration; the State adopted that recommendation at sentencing.
Hoxsey asked for suspended sentences; the district court ordered immediate incarceration based on his criminal history and jail noncompliance.
Hoxsey appealed, arguing the court abused its discretion by refusing to suspend his sentences.
The appeal raised a jurisdictional question under Iowa Code § 814.6(1)(a)(3) (appeals after guilty pleas require the defendant to establish "good cause"); the State conceded jurisdiction.
The Court of Appeals affirmed the sentence, concluding no abuse of discretion and that jurisdiction was proper under controlling precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction: May Hoxsey appeal after a guilty plea (good-cause requirement)?	State concedes jurisdiction.	Hoxsey did not explicitly brief "good cause" but challenges a discretionary sentence; Damme and Fetner supply good cause.	Court exercises jurisdiction: Damme/Fetner establish good cause for discretionary, non-plea‑agreed sentences; State's concession noted.
Abuse of discretion in sentencing: Should the court have suspended the sentence?	PSI and State recommended incarceration based on extensive criminal history and prior incarcerations; immediate incarceration is appropriate.	Hoxsey argued mitigating factors (time served, acceptance of responsibility, community programs, rehabilitation concerns).	No abuse of discretion: sentencing decision within statutory limits and supported by permissible reasons (criminal history, prior sentences, jail noncompliance).

State v. Damme, 944 N.W.2d 98 (Iowa 2020) (holding good cause exists to appeal a discretionary sentence following a guilty plea when sentence is not mandatory or plea‑agreed)
State v. Fetner, 959 N.W.2d 129 (Iowa 2021) (affirming Damme and treating good cause satisfied for such sentencing appeals)
Crowell v. State Pub. Def., 845 N.W.2d 676 (Iowa 2014) (appellate courts must sua sponte police jurisdiction)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sentences within statutory limits carry a strong presumption of correctness; review for abuse of discretion)
State v. Thompson, 951 N.W.2d 1 (Iowa 2020) (clarifying Damme's scope: good cause applies when sentence is discretionary and not plea‑agreed)
State v. Tucker, 959 N.W.2d 140 (Iowa 2021) (noting defendant bears the burden to establish good cause on appeal)