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State v. Patterson
Citations: 586 N.W.2d 83; 1998 Iowa Sup. LEXIS 225; 1998 WL 650888Docket: 97-846
Court: Supreme Court of Iowa; September 23, 1998; Iowa; State Supreme Court
Glenn Michael Patterson appeals his sentencing after pleading guilty to three counts of serious domestic abuse assault. The Iowa Supreme Court addresses the legality of the sentencing court's designation of the county jail as the place of confinement for Patterson's consecutive sentences, which total 420 days. Under Iowa Code section 903.4, individuals sentenced to more than one year must be committed to the custody of the Iowa Department of Corrections. Although each of Patterson's individual sentences was less than one year, the consecutive nature of the sentences effectively results in a total exceeding one year, necessitating confinement under the Department of Corrections. The State argued that because Patterson's sentences were suspended, the designation of the county jail was appropriate. However, the Court clarified that the suspension does not change the classification of the sentences as confinement sentences. Therefore, the sentencing court erred by designating the county jail for confinement. The Court affirms Patterson's convictions but vacates the sentences and remands the case for resentencing, ensuring the correct designation of confinement.