State of Iowa v. Stephen Robert Bloomer
14-1598
| Iowa Ct. App. | Nov 9, 2016Background
- Stephen Bloomer pleaded guilty (per plea agreement) to manufacturing a controlled substance (marijuana) in July 2014; other charges were dismissed.
- Sentencing was continued for a presentence investigation (PSI); PSI documented a lengthy criminal history dating to 1983, prior marijuana manufacturing conviction (2004), alcohol/drug offenses, and conviction as a sex offender.
- PSI author recommended incarceration and observed Bloomer downplayed his criminal behavior and had repeatedly received leniency without rehabilitation.
- At sentencing the district court adopted the PSI’s observations, cited Bloomer’s substantial criminal history, recidivism, age, and lack of grasp of his conduct’s severity, and imposed up to five years’ incarceration.
- Bloomer appealed, arguing the court failed to consider all relevant sentencing factors on the record (including his minor role and motive to help a sick friend) and that the sentence was unduly harsh given changing marijuana law and claimed mitigating circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentencing court failed to consider all relevant factors on the record | Court (State) argued the record and PSI show the court considered pertinent factors like criminal history and rehabilitation prospects | Bloomer argued the court did not address nature of offense, attending circumstances, and his minor role/motive on the record | Court held no abuse: judge adopted PSI, considered criminal history and mitigation need not be recited point-by-point; record adequate for review |
| Whether the sentence was unduly harsh | State argued sentence was within statutory limits and justified by recidivism and prior similar conviction | Bloomer argued sentence excessive given legalization trends, medical benefits, and his motive to help an ill friend | Court held sentence lawful and presumptively valid because within statutory limits; no abuse of discretion |
Key Cases Cited
- State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (standard for appellate review of sentencing and presumption favoring sentences within statutory limits)
- State v. Boltz, 842 N.W.2d 9 (Iowa Ct. App.) (failure to explicitly acknowledge a sentencing circumstance does not necessarily mean it was not considered)