State of Iowa v. Maddison Mary Miller, 17-0035

Maddison Miller pled guilty to fourth-degree theft (serious misdemeanor); district court granted a deferred judgment and one year probation, including a $315 civil penalty.
First probation-violation report (consumption of alcohol) led Miller to stipulate; court found contempt and ordered 10 days jail but continued probation and set conditions to purge contempt with a February hearing.
A second violation report alleged further alcohol use and lying to a probation officer; DCS sought revocation and Miller stipulated to the second violation.
On December 8 the court revoked the deferred judgment, adjudicated Miller guilty, and sentenced her to 90 days incarceration; the court had earlier imposed the contempt sanction in a separate proceeding.
Miller appealed, arguing the court (1) improperly imposed multiple 908.11(4) consequences, (2) relied on unsupported grounds, (3) failed to credit the civil penalty against a fine, and (4) abused discretion in sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court may impose multiple 908.11(4) consequences	State: separate proceedings allow separate remedies	Miller: court violated Keutla by imposing more than one consequence	Court: No error — contempt and revocation were imposed in separate proceedings, so each could trigger a remedy under 908.11(4)
Whether sentencing relied on unsupported grounds	State: court considered legitimate factors (public protection, Miller’s statement, substance-abuse history)	Miller: court relied on mistaken facts (max probation expired, outstanding court debt)	Court: No legal error; the disputed factual note was not a sentencing consideration
Whether Miller should have received credit for the $315 civil penalty when a fine was imposed	State: scrivener’s error likely; record unclear	Miller: order failed to convert/credit civil penalty against imposed fine	Court: Vacated portion of order as unclear about fine and credit; remanded for corrected judgment entry (no resentencing needed)
Whether revocation and sentence were an abuse of discretion	State: supported by stipulations, substance-abuse history, prior supervision for DUI/child-endangerment	Miller: insufficient record support for considerations used	Court: No abuse of discretion; record supports the court’s reliance on Miller’s stipulations, substance-abuse history, and public-protection concern

State v. Keutla, 798 N.W.2d 731 (Iowa 2011) (district court may choose only one remedy under section 908.11(4) for a single probation-violation proceeding)
State v. Wade, 757 N.W.2d 618 (Iowa 2008) (a sentencing order must be legally sufficient and clear; ambiguous sentences may be vacated)