State of Iowa v. William C. Colvin Jr., 16-1110

William C. Colvin Jr., age 28, pleaded guilty to third-degree sexual abuse of a 14-year-old household member and was immediately sentenced on May 23–24, 2016.
At the oral sentencing the court suspended a $250 civil sex-offender penalty, imposed a ten-year suspended sentence, five years probation, sex‑offender treatment, victim restitution, a $100 surcharge under Iowa Code § 911.2B, and court costs to be set by the clerk.
The written sentencing order mistakenly required payment of the $250 civil penalty that had been suspended at the oral pronouncement.
Colvin agreed to a DCS restitution plan to pay $50/month toward $350 in court costs; he filed a notice of appeal on June 10, 2016.
After the appeal, Colvin performed community service and the clerk’s online docket shows community service credits extinguished the $490 in assessed court costs; the State argued this made Colvin’s challenges moot.
The district court approved the community-service credits; the appellate court reviewed the restitution issues for errors of law and dismissed the appeal as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether written order’s $250 civil penalty conflicts with oral pronouncement	State: Oral pronouncement controls; but moot because Colvin satisfied obligations by community service	Colvin: Written order imposes $250 despite oral suspension; seeks correction and remand	Court: Oral pronouncement governs, and issue is moot because community service discharged the obligation — appeal dismissed
Whether court erred by ordering restitution/costs without determining ability to pay	State: Colvin voluntarily entered restitution plan and then performed community service to satisfy costs; reasonable-ability-to-pay issue moot	Colvin: Trial court failed to determine his reasonable ability to pay and unclear which obligations could be satisfied by community service; asks remand for ability-to-pay hearing	Court: No justiciable controversy remains—community service credits extinguished assessed costs—so ability-to-pay claim is moot

State v. Jenkins, 788 N.W.2d 640 (Iowa 2010) (framework for restitution/statutory mandate)
State v. Hess, 533 N.W.2d 525 (Iowa 1995) (oral pronouncement of sentence controls over written judgment)
State v. Dudley, 766 N.W.2d 606 (Iowa 2009) (court costs included in restitution; ability-to-pay considerations)
State v. Wilson, 234 N.W.2d 140 (Iowa 1975) (mootness: no justiciable controversy when issues become academic)
In re L.H., 480 N.W.2d 43 (Iowa 1992) (consideration of post‑appeal events for mootness purposes)
State v. Sorensen, 436 N.W.2d 358 (Iowa 1989) (judicial notice on appeal)