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State of Iowa v. Zachary Scott Penning
Citation: Not availableDocket: 15-1660
Court: Court of Appeals of Iowa; August 17, 2016; Iowa; State Appellate Court
Original Court Document: View Document
Zachary Penning appeals his sentence for domestic abuse assault, classified as an aggravated misdemeanor under Iowa Code section 708.2A(3)(b) (2015). He argues that the district court abused its discretion by imposing the sentence according to a plea agreement without providing detailed reasons on the record. Penning was charged with domestic abuse assault, second offense, and entered a guilty plea as part of a plea agreement where the State recommended a one-year sentence with thirty days to be served and two years of formal probation. The court accepted the plea and sentenced him according to the agreement, citing "nature of offense, plea agreement, and prior record" as reasons. The court's standard of review indicates that a sentence will not be reversed unless there is an abuse of discretion or a defect in the sentencing procedure. The Iowa Supreme Court has established that if a court simply imposes a sentence based on a plea agreement, it is not required to provide a detailed explanation unless it departs from that agreement. Penning requests a reinterpretation of Iowa Rule of Criminal Procedure 2.23(3)(d) to mandate a statement of reasons even when adhering to a plea agreement, but the appellate court affirms that it cannot overturn Supreme Court precedent. The appellate court concludes that the district court did provide sufficient reasoning, and the sentence is affirmed, noting that even if they were allowed to overrule precedent, the reasons provided would still support the sentence.