State of Iowa v. Loren Patrick Cramblit, 17-0048

Defendant Loren Cramblit rented a West Des Moines home; owner Shane O’Malley found the property vandalized in Feb. 2016 and police linked Cramblit to the damage.
Cramblit was originally charged with criminal mischief in the first degree; he agreed to plead guilty to the lesser included offense of third-degree criminal mischief (an aggravated misdemeanor).
Cramblit initially entered a written plea in June 2016, then successfully moved in arrest of judgment; he later filed a new written guilty plea on November 10, 2016 admitting he spray‑painted a wall causing $500–$1000 in damage.
The plea form included an explicit warning that to challenge the plea the defendant must file a motion in arrest of judgment within a set time before sentencing.
The court accepted the second guilty plea and sentenced Cramblit to 365 days in jail with all but 30 days suspended, plus probation. Cramblit appealed claiming (1) inadequate factual basis for the plea and (2) an illegal sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant preserved challenge to factual basis for guilty plea	State: defendant failed to file a timely motion in arrest of judgment, so issue is forfeited	Cramblit: plea lacked adequate factual basis to support conviction	Forfeiture – defendant did not preserve the claim by motion in arrest of judgment and is precluded from raising it on appeal
Whether the written plea/failure to seek immediate sentencing waived collateral challenges	State: written plea substantially complied with notice requirements; defendant had prior experience filing such a motion	Cramblit: argues plea was not knowing/voluntary because consequences were not fully explained	Court: written plea and prior motion put defendant on notice; substantial compliance satisfied; waiver applies
Whether sentencing to a determinate term for an aggravated misdemeanor was illegal	State: aggravated misdemeanor allows imprisonment up to two years and may include a determinate sentence of up to one year which can be suspended	Cramblit: an aggravated misdemeanor yields an indeterminate sentence and cannot be partially suspended	Court: statutes and precedent allow a determinate sentence of one year or less for an aggravated misdemeanor and suspension/ probation of part of it; sentence was lawful
Overall relief requested (vacatur/reversal)	State: conviction and sentence should stand	Cramblit: vacate conviction or sentence as illegal	Court: affirmed conviction and sentence

State v. Schminkey, 597 N.W.2d 785 (Iowa 1999) (trial court must determine factual basis before accepting a guilty plea)
State v. Keene, 629 N.W.2d 360 (Iowa 2001) (standard of review for plea challenges is correction of errors at law)
State v. Meron, 675 N.W.2d 537 (Iowa 2004) (failure to file timely motion in arrest of judgment precludes appellate challenge to plea)
State v. Fisher, 877 N.W.2d 676 (Iowa 2016) (substantial compliance standard for advising defendants of rights/waivers)
State v. Miller, 590 N.W.2d 724 (Iowa 1999) (defendant precluded from challenging plea on appeal when motion in arrest not filed)
State v. Morris, 416 N.W.2d 688 (Iowa 1987) (review standard for challenges to sentence beyond statutory authority)
State v. Erickson, 362 N.W.2d 528 (Iowa 1985) (aggravated misdemeanor may include determinate sentence of not more than one year)
State v. Shield, 368 N.W.2d 721 (Iowa 1985) (recognizing determinate one‑year sentence as possible for aggravated misdemeanor)
State v. Steuk, 368 N.W.2d 171 (Iowa 1985) (court may suspend part of a determinate sentence and place defendant on probation)