Harold Eugene Meyer v. State of Iowa

CourtCourt of Appeals of Iowa
DecidedOctober 16, 2024
Docket23-1053
StatusPublished

This text of Harold Eugene Meyer v. State of Iowa (Harold Eugene Meyer v. State of Iowa) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harold Eugene Meyer v. State of Iowa, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1053 Filed October 16, 2024

HAROLD EUGENE MEYER, Applicant-Appellant,

vs.

STATE OF IOWA, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Jasper County, Charles Sinnard,

Judge.

A sex offender appeals the denial of his application to end his registration

obligation. AFFIRMED.

Philip B. Mears of Mears Law Office, Iowa City, for appellant.

Brenna Bird, Attorney General, and Timothy M. Hau, Assistant Attorney

General, for appellee State.

Considered by Tabor, C.J., and Greer and Schumacher, JJ. 2

TABOR, Chief Judge.

Harold Meyer appeals the denial of his request to modify his status on the

sex offender registry. The district court determined that Meyer was not eligible for

modification under Iowa Code section 692A.128(2)(b) (2022) because he did not

complete required sex offender treatment programs. Meyer argues that he was

not required to attend sex offender treatment while incarcerated under the

reasoning of two Iowa Supreme Court cases from 2009 addressing eligibility for

earned time. But those cases are not controlling. Because substantial evidence

supports the district court’s determination that Meyer was required to participate in

sex offender treatment and refused, he did not meet the threshold test for

modification. We thus affirm the denial of his request to end his registration

requirement.

I. Facts and Prior Proceedings

In 1998, Meyer pleaded guilty to first-degree burglary, third-degree

kidnapping, false imprisonment, and third-degree sexual abuse. The district court

imposed concurrent terms not to exceed twenty-five years.

While incarcerated, the Iowa Department of Corrections (DOC) informed

Meyer that he needed to complete the Sex Offender Treatment Program (SOTP)

because he was convicted of a sexual offense. In 2007, Meyer signed a refusal

form that outlined his requirement to complete SOTP. Later, the fifth judicial district

department of correctional services prepared an assessment report showing

Meyer did not complete the required programming.

Meyer discharged his sentence in 2009. That same year, his requirement

to register as a sex offender began. 3

More than a decade later, Meyer applied to modify his registration

requirement under section 692A.128. In 2023, the district court denied Meyer’s

application, finding Meyer failed to satisfy a threshold criterion for modification.

The unfulfilled condition was Meyer’s failure to complete the required SOTP while

incarcerated. Meyer appeals.

II. Scope and Standard of Review

We review the district court’s interpretation of section 692A.128 for the

correction of legal error. Fortune v. State, 957 N.W.2d 696, 702 (Iowa 2021). We

review its findings of fact for substantial evidence; those findings bind us if

supported by the record. See State v. Smith, 926 N.W.2d 760, 762 (Iowa 2019).

III. Analysis

Section 692A.128 governs the modification of sex-offender registration

requirements. That statute allows sex offenders to apply for modification if they

meet these five requirements.

a. The date of the commencement of the requirement to register occurred at least two years prior to the filing of the application for a tier I offender and five years prior to the filing of the application for a tier II or tier III offender. b. The sex offender has successfully completed all sex offender treatment programs that have been required. c. A risk assessment has been completed and the sex offender was classified as a low risk to reoffend. The risk assessment used to assess an offender as a low risk to reoffend shall be a validated risk assessment approved by the department of corrections. d. The sex offender is not incarcerated when the application is filed. e. The director of the judicial district department of correctional services supervising the sex offender, or the director’s designee, stipulates to the modification, and a certified copy of the stipulation is attached to the application.

Iowa Code § 692A.128(2)(a)–(e). 4

When an offender seeks modification, the district court may hold a hearing

to probe whether the offender met those gateway elements. Fortune, 957 N.W.2d

at 705. The court must consider the factors together, and if any are not satisfied,

the court must deny modification as a threshold matter. Id.

At issue here is the second element—completion of required treatment

programs. That issue turns on what the legislature meant by “required” treatment

programs. Meyer argues the DOC could not require him to complete SOTP under

the rationale of State v. Iowa Dist. Ct. for Henry Cnty., 759 N.W.2d 793

(Iowa 2009), and Holm v. Iowa Dist. Ct., 767 N.W.2d 409 (Iowa 2009). Those

cases addressed Iowa Code section 903A.2, which authorizes sentence

reductions for good conduct and satisfactorily participating in specified programs.

Those reductions are known as “earned time.” Iowa Dist. Ct. for Henry Cnty., 759

N.W.2d at 795. The supreme court held that 2001 and 2005 amendments to

section 903A.2—making offenders ineligible for earned-time credits if they did not

complete SOTP—violated the ex post facto clause applied to inmates incarcerated

before 2001. Id. at 802. In Holm, the court clarified that the amendments did not

violate the ex post facto clause when applied to inmates incarcerated before the

2005 amendment but after the 2001 amendment. 767 N.W.2d at 418.

Meyer contends that those cases erase any requirement that he participate

in SOTP as a condition of modification under section 692A.128(2)(b). According

to Meyer, because his incarceration began before 2001, he was not required to

complete SOTP. Meyer points to a DOC form he received in 2007 that referenced

the 2005 amendment to section 903A.2. That form advised that he needed to 5

complete SOTP otherwise he would stop accruing earned time.1 Since that form

relied on the earned-time amendment—found to be unconstitutional—Meyer

contends it cannot serve as the source of the SOTP requirement for the registration

statute. In other words, Meyer argues that he should not have been required to

participate in SOTP to qualify for modification under section 692A.128(2)(b).

Meyer’s reliance on Iowa Dist. Ct. for Henry Cnty. is misplaced. Its ex post

facto analysis applies only to limitations on earned time for failing to complete

SOTP. See 759 N.W.2d at 799–802 (discussing section 903A.2). Neither Iowa

Dist. Ct. for Henry Cnty. nor Holm speak to the constitutionality of requiring SOTP.

Instead, those cases concern the constitutionality of denying an inmate earned

time credits for failing to complete SOTP if incarcerated before 2001. See id. at

793; Holm, 767 N.W.2d at 409. In fact, Iowa Dist. Ct. for Henry Cnty. makes this

distinction apparent:

[The inmate] does not claim that requiring him to participate in the SOTP is itself a violation of the Ex Post Facto Clause. Cf. Schreiber v.

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Related

Atwood v. Vilsack
725 N.W.2d 641 (Supreme Court of Iowa, 2006)
Smith v. State
760 N.W.2d 211 (Court of Appeals of Iowa, 2008)
State v. Iowa District Court for Henry County
759 N.W.2d 793 (Supreme Court of Iowa, 2009)
Holm v. Iowa District Court for Jones County
767 N.W.2d 409 (Supreme Court of Iowa, 2009)
State v. Pickens
558 N.W.2d 396 (Supreme Court of Iowa, 1997)
Schreiber v. State
666 N.W.2d 127 (Supreme Court of Iowa, 2003)
State of Iowa v. Keegan Craig Smith
926 N.W.2d 760 (Supreme Court of Iowa, 2019)

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