State of Iowa v. Patrick John Letscher, 888 N.W.2d 880

Patrick Letscher posted a $2,000 cash appearance bond after arrest on theft charges and signed a clerk-provided bond form containing language authorizing use/forfeiture of the bond to pay court-ordered obligations.
Letscher pleaded guilty to first-degree theft pursuant to a plea agreement; the district court sentenced him to incarceration (no probation) and ordered monetary obligations (fine, surcharges, restitution, attorney fees).
Paragraph 6 of the sentencing order stated the appearance bond was forfeited and applied to Letscher’s obligations in this and other Winnebago County criminal matters.
Letscher appealed, arguing (1) the district court improperly denied probation based on a fixed policy and (2) the court lacked authority to order forfeiture of the pretrial bond as part of sentencing.
The court of appeals affirmed; the Iowa Supreme Court granted further review, affirmed the court of appeals on the probation issue, but found the district court lacked statutory authority to forfeit bail as a term of sentence.
The Supreme Court struck paragraph 6 of the sentencing order, remanded for proceedings consistent with statutory bail procedures (including clerks’ disbursement rules and separate civil forfeiture process), and otherwise affirmed the judgment and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion in denying probation	State: denial supported by circumstances and presentence recommendation	Letscher: court applied a fixed policy against probation for prior record	Held: No abuse; affirmed on this issue
Whether a sentencing court may forfeit a pretrial cash appearance bond to satisfy sentence obligations	State: bond form and consent authorized applying bond; court may direct disposition	Letscher: court lacks statutory authority to forfeit bail as part of sentence	Held: District court lacked statutory authority; paragraph ordering forfeiture struck and remanded for proper bail procedures

State v. Gathercole, 877 N.W.2d 421 (Iowa 2016) (discretion to select issues on further review)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (review standard for sentencing and distinction of collateral post-sentence matters)
State v. Briggs, 666 N.W.2d 573 (Iowa 2003) (abuse-of-discretion review for bail-related court decisions)
State v. Costello, 489 N.W.2d 735 (Iowa 1992) (forfeiture of bail is a civil action)
State v. Alspach, 554 N.W.2d 882 (Iowa 1996) (distinguishing sentencing orders from later collateral proceedings)
State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (sentence illegal if not statutorily authorized)