State of Iowa v. Mychael Richard Patten, 981 N.W.2d 126

Defendant Mychael Patten pleaded guilty to multiple charges (domestic abuse assault, child endangerment, assault with a dangerous weapon, false imprisonment) in exchange for the State's joint recommendation of suspended sentences with conditions (mental health evaluation/treatment, no-contact order).
At sentencing the prosecutor asked the court to adopt the plea agreement but repeatedly stated the "sole reason" or "sole driving force" for the recommendation was the victim’s expressed desire that Patten remain part of the child’s life.
The district court rejected suspended sentences and imposed an aggregate prison term; the court said it considered the prosecutor’s comments but otherwise relied on factors like prior record and seriousness of offenses.
Patten appealed, claiming the prosecutor breached the plea agreement by qualifying the State’s recommendation; the court of appeals affirmed focusing on lack of effect on sentencing.
The Iowa Supreme Court granted further review, held the prosecutor breached the plea agreement by expressing material reservations and conveying the recommendation as coming from the victim rather than the State, and ordered resentencing before a different judge while affirming the conviction.

Issue	State's Argument	Patten's Argument	Held
Whether the prosecutor breached the plea agreement by qualifying the recommended suspended sentences as driven solely by the victim’s wishes	The prosecutor merely explained the State’s motivation and did recommend adoption of the plea agreement	The prosecutor expressed material reservations and effectively passed off the recommendation as the victim’s, not the State’s	Breach: prosecutor’s repeated framing that the victim was the "sole" reason conveyed material reservations and deprived Patten of the bargained-for recommendation
Remedy for breach	No resentencing necessary because the court was not influenced; any error was harmless	Resentencing before a different judge with the prosecutor bound to honor the recommendation	Remedy granted: sentence vacated and remanded for resentencing before a different judge; conviction affirmed

Santobello v. New York, 404 U.S. 257 (1971) (prosecutorial breach of plea agreement requires resentencing even if judge claims non-influence)
State v. King, 576 N.W.2d 369 (Iowa 1998) (breach mandates a new sentencing hearing despite claimed lack of influence)
State v. Horness, 600 N.W.2d 294 (Iowa 1999) (prosecutor must present and commend agreed sentences and indicate State support)
State v. Boldon, 954 N.W.2d 62 (Iowa 2021) (prosecutor must not inject material reservations into a promised recommendation)
State v. Fannon, 799 N.W.2d 515 (Iowa 2011) (State cannot cure a plea-breach by withdrawing improper comments)
State v. Lopez, 872 N.W.2d 159 (Iowa 2015) (remedy for breach can include resentencing before a different judge)
State v. Davis, 971 N.W.2d 546 (Iowa 2022) (appeal claiming a sentencing-recommendation breach constitutes good cause to appeal)