State of Iowa v. Michael Anthony Williams, 16-1560

Michael Williams pleaded guilty to second-degree robbery (Class C) and first-degree burglary (Class B) pursuant to a plea agreement that included consecutive sentences.
A 2016 change in Iowa law made the robbery mandatory-minimum percentage discretionary; parties left the mandatory-minimum length to the court’s discretion at sentencing.
At sentencing the court considered whether to impose a 50% or 70% mandatory minimum and selected a five-year (50%) minimum on the ten-year robbery term.
The court then stated it would “sentence the defendant in accordance with the parties’ plea agreement” and imposed a consecutive 25-year indeterminate term for burglary plus fines and fees.
Williams appealed, arguing the court abused its discretion by failing to state on the record reasons for ordering the sentences to run consecutively.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing court abused discretion by failing to state reasons for consecutive sentences	State: Court followed plea agreement and properly incorporated its terms into the record	Williams: Court failed to articulate reasons for consecutive sentences, so sentencing was defective	Affirmed — no abuse: court incorporated plea agreement particulars into the record; Hill distinguished

State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (standard of appellate review for sentencing is correction of errors at law)
State v. Wright, 340 N.W.2d 590 (Iowa 1983) (sentence will be overturned only for abuse of discretion or procedural defect)
State v. Evans, 672 N.W.2d 328 (Iowa 2003) (definition of abuse of discretion)
State v. McGonigle, 401 N.W.2d 39 (Iowa 1987) (requirement that court state reasons for sentence on the record)
State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (court must state at least a cursory explanation when imposing consecutive or concurrent sentences)
State v. Hill, 878 N.W.2d 269 (Iowa 2016) (sentencing court must explain resolution when parties dispute appropriate sentence)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (plea-agreement particulars must be made part of sentencing record)
State v. Cason, 532 N.W.2d 755 (Iowa 1995) (same principle regarding plea agreements and sentencing record)
State v. Snyder, 336 N.W.2d 728 (Iowa 1983) (longstanding rule requiring plea agreement particulars on the record)