State of Iowa v. Michael A. McCann, 16-1485

Michael McCann pled guilty to four counts of delivery of a controlled substance and one count of possession with intent to deliver under Iowa Code §124.401(1)(d).
At sentencing the State recommended five-year terms on each count, to be served consecutively; McCann asked for concurrent sentences.
The district court imposed five-year terms on the four delivery counts to run concurrently, and a five-year term on the possession-with-intent count to run consecutively, for a total of ten years.
In announcing sentence, the court explained it sought to balance rehabilitation and deterrence, treating the needs of McCann and the community as bases for running Count V consecutive.
McCann appealed, arguing the district court failed to adequately explain its reasons for imposing a consecutive sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court gave adequate reasons for imposing a consecutive sentence	State: The court’s explanation that consecutive time was necessary for rehabilitation and deterrence and considered defendant/community needs was sufficient	McCann: The court’s explanation was inadequate and did not sufficiently state specific reasons for consecutive sentence	The court affirmed; the district court’s terse explanation was adequate to allow appellate review and showed it balanced rehabilitation and deterrence against the parties’ arguments

State v. Hill, 878 N.W.2d 269 (Iowa 2016) (sentencing courts should explicitly state reasons for imposing consecutive sentences)
State v. Seats, 865 N.W.2d 545 (Iowa 2015) (standard of review for within-guideline sentences)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (a terse statement can suffice if it permits review)
State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (reasons must permit appellate review of the court’s discretionary decision)
State v. Johnson, 445 N.W.2d 337 (Iowa 1989) (brevity acceptable so long as it does not prevent review)