882 N.W.2d 123
Iowa Ct. App.2016Background
- Stephanie Fatland pleaded guilty to two counts of child endangerment resulting in bodily injury after alleged shaking incidents involving her five‑month‑old; a third charge was dismissed under a plea agreement.
- The district court imposed consecutive five‑year prison terms but suspended them and placed Fatland on five years’ probation.
- Probation conditions included: no unsupervised contact with children under age five, and prohibition on becoming pregnant while on probation.
- Fatland moved to reconsider the pregnancy condition, arguing it infringed her fundamental right to procreate; the court denied the motion.
- Fatland appealed only the probation conditions; the convictions were not challenged on appeal.
- The Court of Appeals reviewed the probation conditions for abuse of discretion and affirmed the convictions but vacated and remanded for resentencing as to the challenged conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a probation condition barring all unsupervised contact with children under age five is reasonable | The State implicitly argued the restriction is related to the offense and rehabilitation | Fatland argued the condition is overbroad, lacks exceptions for incidental/innocuous contact, and unduly restricts daily life | Vacated and remanded for a narrower, more precise condition that includes an exception for incidental contact in public where responsible adults are present |
| Whether a probation condition forbidding pregnancy during probation is lawful | The State conceded the condition was unreasonable | Fatland argued the condition violates her fundamental right to procreation | Vacated the pregnancy prohibition as unconstitutional/intrusive on procreation rights |
| Whether convictions should be disturbed based on challenged conditions | State sought to uphold convictions and conditions | Fatland sought relief from the conditions but not reversal of convictions | Convictions affirmed; sentencing order vacated and remanded for resentencing consistent with opinion |
Key Cases Cited
- State v. Lathrop, 781 N.W.2d 288 (Iowa 2010) (probation conditions must be reasonably related to the offense and not overbroad; court remanded to fashion more precise no‑contact condition)
- State v. Hall, 740 N.W.2d 200 (Iowa Ct. App. 2007) (upheld condition with an explicit exception for incidental contact in public; struck/amended ambiguous restrictions on communication)
- People v. Zaring, 10 Cal. Rptr. 2d 263 (Cal. Ct. App. 1992) (probation condition prohibiting pregnancy is unlawful and must be stricken)
- State v. Oakley, 629 N.W.2d 200 (Wis. 2001) (upheld a narrowly tailored reproductive‑related condition tying future children to demonstrated ability to support them)