State v. Lange, 2013 Iowa App. LEXIS 387

Lange pled guilty to extortion in November 1996 and received a deferred judgment with two years of supervised probation.
Lange requested transfer of probation to Minnesota, but transfer was not completed.
January 1997 Lange was arrested in Minnesota for minor consumption and obstructing legal process and was convicted on those charges; Minnesota did not accept probation transfer due to new charges.
May 1997 revocation hearing: Lange’s probation was not revoked but he was found in contempt and sentenced to two days in jail.
A second transfer attempt failed; Lange did not contact his Iowa probation officer; December 1997 State again sought revocation.
In 2012, Lange was arrested in Minneapolis on a felony drug charge; upon return to Iowa, the court revoked the deferred judgment and sentenced Lange to five years in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court consider all evidentiary factors in revoking the deferred judgment and imposing sentence?	Lange contends the court failed to consider all evidentiary factors.	State argues court did consider Lange's history and allocution in its ruling.	No abuse; court adequately considered factors.
Was the five-year prison sentence an abuse of discretion?	Lange challenges the reasonableness of the sentence.	State argues within statutory limits and supported by factors.	No abuse; sentence affirmed.
Were Lange's appellate brief rule violations material to disposition?	Lange's brief violates appellate rules.	State urges dismissal or waiver if warranted.	Court addressed merits despite defects.

State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (sanctions reviewing sentencing discretion; abuse of discretion requires untenable grounds)
State v. Bentley, 757 N.W.2d 257 (Iowa 2008) (limits on factors for sentencing; proper consideration of appropriate factors)
Inghram v. Dairyland Mut. Ins. Co., 215 N.W.2d 239 (Iowa 1974) (procedural rule violations can lead to waiver or disposition)