State of Iowa v. Zachary Alan Becker, 19-1583

Becker pled guilty to OWI (third or subsequent) and driving while barred; sentencing occurred Sept. 2019.
At sentencing the court orally imposed indeterminate terms: not to exceed five years (OWI) and two years (driving while barred), ordered to run consecutively (total not to exceed seven years).
The written judgment incorrectly stated the counts would run concurrently. Under Iowa law the oral pronouncement controls when there is a discrepancy.
Underlying facts: Becker hit another vehicle and fled; a passenger required ambulance transport; Becker admitted recent alcohol use and had an open beer in the car; he claimed he hit a raccoon.
Becker had multiple prior OWI and driving-while-barred convictions and a history of eluding; PSI showed continued alcohol use, resistance to treatment, and prior completion of the OWI program without lasting benefit.
Becker appealed only his sentences, arguing the court failed to state adequate reasons considering mitigating factors; the court affirmed and remanded for a nunc pro tunc order to reflect consecutive sentences.

Issue	Plaintiff's Argument	Becker's Argument	Held
Whether the sentencing court stated adequate reasons on the record to support the imposed sentences	State: Court sufficiently considered goals (punishment, rehabilitation, deterrence, protection), PSI, counsel arguments, victim impact, and defendant's history; sentence within discretion	Becker: Court failed to address his age, education, employment, family, other mitigating factors, and did not explain how sentence fits him or protects community	Court: No abuse of discretion; judge explained balancing of sentencing goals, considered PSI and statements, and permissibly rejected alternatives
Whether the written judgment or the oral pronouncement controls when they conflict	State: Oral pronouncement governs; correct remedy is nunc pro tunc entry	Becker: Relied on written order stating concurrent terms (argued inconsistency)	Court: Oral pronouncement controls; affirmed sentence and remanded to correct written judgment to reflect consecutive terms

State v. Damme, 944 N.W.2d 98 (Iowa 2020) (date of judgment controls applicability of amended appeal statute; good cause exists to appeal sentence after a guilty plea)
State v. Majors, 940 N.W.2d 372 (Iowa 2020) (sentencing decisions afford strong presumption and are reviewed for abuse of discretion)
State v. Roby, 897 N.W.2d 127 (Iowa 2017) (abuse of discretion occurs when court ignores relevant factors, gives weight to improper factors, or imposes a sentence outside limited range)
State v. Hess, 533 N.W.2d 525 (Iowa 1995) (oral sentencing pronouncement controls over conflicting written judgment)
State v. Crooks, 911 N.W.2d 153 (Iowa 2018) (trial court need not explain rejection of particular alternative sentence when it explains chosen sentence)