State of Iowa v. Shaunta Rose Hopkins
860 N.W.2d 550
| Iowa | 2015Background
- Hopkins was convicted at trial of six drug offenses, including conspiracy to deliver crack cocaine and possession of controlled substances.
- One conviction for conspiracy to deliver ecstasy was reversed on appeal in 2012, leaving five convictions intact.
- At resentencing, the court used the original December 2011 PSI for the five non-reversed convictions, with Hopkins submitting new mitigating evidence but no new PSI prepared.
- The district court imposed five concurrent sentences identical to the original, except for omitting the five-year count associated with the reversed conviction.
- Hopkins argued the court abused its discretion and that counsel was ineffective for not objecting to the use of the old PSI; the State argued rehabilitation and changed circumstances supported the sentence.
- The Iowa Court of Appeals affirmed; the Supreme Court granted review to consider abuse of discretion and ineffective-assistance claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in resentencing | Hopkins | Hopkins | No abuse; sentence within statutory bounds, with consideration of rehabilitation and circumstances. |
| Whether Hopkins received ineffective assistance of counsel for failing to object to the PSI use | Hopkins | Hopkins | Record inadequate to decide; decline to grant relief on direct appeal. |
Key Cases Cited
- State v. August, 589 N.W.2d 740 (Iowa 1999) (factors for sentencing include age, character, and rehabilitation)
- State v. Harrington, 805 N.W.2d 391 (Iowa 2011) (recognizes changed circumstances in resentencing and aggregate approach)
- State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (rehabilitation and changed circumstances may mitigate punishment)
- Pepper v. United States, 131 S. Ct. 1229 (2011) (postsentencing rehabilitation may be considered in sentencing)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (demonstrated maturity and rehabilitation considerations in sentencing)
- State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (juvenile rehabilitation considerations; distinguish adult sentencing)
- State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sentencing discretion and rehabilitation as a factor)
- State v. Doggett, 687 N.W.2d 97 (Iowa 2004) (ineffective-assistance claims require adequate record on direct appeal)
- State v. Fannon, 799 N.W.2d 515 (Iowa 2011) (prejudice standard for ineffective assistance on appeal)