State of Iowa v. Shane W. Trimble, 16-2181

On January 14, 2016, Cedar Rapids police stopped Shane Trimble after a license-plate check showed he was driving a stolen vehicle; DOT records showed he was barred from driving.
The State charged Trimble with driving while barred under Iowa Code §§ 321.560, 321.561; Trimble pled guilty on December 7 and executed a waiver of rights.
The plea described an agreement of 60 days in jail with credit, 300 days suspended, a minimum fine, and one year unsupervised probation.
The court accepted the guilty plea and sentenced Trimble to 360 days imprisonment, suspending all but 60 days, consistent with the parties’ plea agreement.
Trimble appealed, arguing the sentence was inappropriate and the sentencing court abused its discretion by failing to state reasons on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was appropriate	Sentence within statutory limits and consistent with plea agreement; discretionary and supported	Sentence inappropriate given circumstances	Court affirmed; sentence within statutory guidelines and supported by plea agreement
Whether court abused discretion by failing to state reasons on the record	Written sentencing order listed factors considered; this was sufficient	Court failed to articulate reasons on the record at sentencing	No abuse of discretion; court considered proper factors in writing and weighed them

State v. Letscher, 888 N.W.2d 880 (Iowa 2016) (standard of review for sentencing within statutory guidelines)
State v. Seats, 865 N.W.2d 545 (Iowa 2015) (sentencing review standard)
State v. Hill, 878 N.W.2d 269 (Iowa 2016) (definition of abuse of discretion)
State v. Hopkins, 860 N.W.2d 550 (Iowa 2015) (presumption in favor of trial court sentencing)
State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (factors trial court must weigh in sentencing)
State v. Snyder, 336 N.W.2d 728 (Iowa 1983) (sentence reflecting plea agreement is effect of parties’ bargain)