Jesus Lozano Campuzano v. Iowa District Court for Polk County

CourtSupreme Court of Iowa
DecidedMarch 12, 2020
Docket18-1985
StatusPublished

This text of Jesus Lozano Campuzano v. Iowa District Court for Polk County (Jesus Lozano Campuzano v. Iowa District Court for Polk County) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jesus Lozano Campuzano v. Iowa District Court for Polk County, (iowa 2020).

Opinion

IN THE SUPREME COURT OF IOWA No. 18–1985

Filed March 12, 2020

JESUS LOZANO CAMPUZANO,

Plaintiff,

vs.

IOWA DISTRICT COURT FOR POLK COUNTY,

Defendant.

Certiorari to the Iowa District Court for Polk County, Jeffrey Farrell,

Judge.

The criminal defendant petitioned for a writ of certiorari after the

district court denied his motion to correct an illegal sentence. WRIT

ANNULLED.

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

Thomas J. Miller, Attorney General, and William A. Hill, Assistant

Attorney General, for defendant. 2

CHRISTENSEN, Chief Justice.

In this case, the criminal defendant pled guilty to possession of

methamphetamine with intent to deliver and to possession or control of a

firearm. His guilty plea to the firearm charge enhanced the drug charge

by doubling his maximum sentence from twenty-five years to fifty years.

A few months after the criminal defendant’s sentencing, the Iowa

legislature amended Iowa Code section 124.413 and created section

901.12. The criminal defendant filed a motion to correct an illegal

sentence, arguing section 901.12 reduced his minimum period of

confinement by one-half. In denying the criminal defendant’s motion, the

district court determined a person sentenced pursuant to the firearm

enhancement was not eligible to receive the one-half reduction. The

criminal defendant petitioned for a writ of certiorari, and we granted

certiorari review.

Upon our review, we interpret sections 124.413 and 901.12 to

reduce the minimum period of confinement for specific drug crimes

without affecting the minimum period of confinement for drug crimes

committed while in the possession of a firearm. We annul the writ.

I. Background Facts and Proceedings.

On April 5, 2016, Jesus Lozano Campuzano pled guilty to

possession of methamphetamine with intent to deliver, in violation of Iowa

Code section 124.401(1)(b)(7) (2014). He also pled guilty to possession or

control of a firearm, in violation of Iowa Code section 124.401(1)(e). Lozano

Campuzano requested immediate sentencing that same day. A violation

of section 124.401(1)(b)(7) is a class “B” felony, which normally carries a

maximum sentence not to exceed twenty-five years. See Iowa Code

§ 902.9(1)(b). However, the twenty-five-year maximum sentence was

doubled by his guilty plea to the firearm charge: 3 A person in the immediate possession or control of a firearm while participating in a violation of this subsection shall be sentenced to two times the term otherwise imposed by law, and no such judgment, sentence, or part thereof shall be deferred or suspended.

Id. § 124.401(1)(e) (emphasis added). In accordance with Iowa law, the

district court sentenced Lozano Campuzano to a period of imprisonment

not to exceed fifty years. It determined Iowa Code section 124.413 imposed

a minimum period of confinement of one-third of the fifty-year sentence.

See Iowa Code § 124.413(1). 1 Lozano Campuzano’s minimum period of confinement was further reduced by one-third because of his guilty plea.

See Iowa Code § 901.10(2). 2 The district court denied probation and

Lozano Campuzano was committed to the custody of the Iowa Department

of Corrections (DOC).

For each offender in custody, DOC creates a time computation

portfolio that estimates the minimum parole date and the tentative

discharge date. The minimum parole date is a calculated date of when the

mandatory period of confinement ends. Prior to the passage of House File

2064, which amended Iowa Code section 124.413 and created section

901.12, DOC calculated Lozano Campuzano would be eligible for parole

approximately five years after his confinement began. The parties do not dispute the DOC calculation expressed below:

1At the time of sentencing, Iowa Code section 124.413(1) stated,

A person sentenced pursuant to section 124.401, subsection 1, paragraph “a”, “b”, “c”, “e”, or “f”, shall not be eligible for parole until the person has served a minimum period of confinement of one-third of the maximum indeterminate sentence prescribed by law. 2Iowa Code section 901.10(2) states, “If the defendant pleads guilty, the court may, at its discretion, reduce the mandatory minimum sentence by up to one-third.” 4

Confinement Calculation Iowa Code Section

25 year maximum 902.9(1)(b) (class “B” felony)

25 x 2 = 50 year maximum 124.401(1)(e) (firearm enhancement)

50 x (1/3) ≈ 17 year minimum 124.413(1) (1/3 minimum period) 901.10(2) 17 – (17 x 1/3) ≈ 11 year minimum (1/3 reduced minimum for guilty plea) 903A.2(1)(a) 11 x (1/2.2) ≈ 5 year minimum (anticipated earned good time)

The dispute in this case concerns the new section 901.12 and whether it

applies to Lozano Campuzano’s firearm enhancement. Section 901.12

amended Iowa law by retroactively reducing particular mandatory

sentences by one-half. See 2016 Iowa Acts ch. 1104, § 7 (codified at Iowa

Code § 901.12 (2017)).

Lozano Campuzano filed a motion to correct an illegal sentence,

arguing section 901.12 reduced his minimum period of confinement by

one-half. If true, Lozano Campuzano would be eligible for parole

approximately two-and-a-half years (instead of five years) after his

confinement. The district court denied Lozano Campuzano’s motion to

correct an illegal sentence. It reasoned his firearm-enhanced sentence was

not eligible for the one-half reduction.

Lozano Campuzano petitioned for a writ of certiorari. We granted

II. Standard of Review.

This case is before us as an original certiorari action. See Iowa R.

App. P. 6.107(1). Therefore, we review the district court’s ruling for

correction of errors at law. State v. Iowa Dist. Ct., 812 N.W.2d 1, 2 (Iowa

2012); Weissenburger v. Iowa Dist. Ct., 740 N.W.2d 431, 434 (Iowa 2007).

A writ of certiorari lies where a lower board, tribunal, or court has exceeded its jurisdiction or otherwise acted illegally. . . . “Illegality exists when the court’s findings lack substantial 5 evidentiary support, or when the court has not properly applied the law.”

Weissenburger, 740 N.W.2d at 434 (quoting State Pub. Def. v. Iowa Dist.

Ct., 721 N.W.2d 570, 572 (Iowa 2006)). Because Lozano Campuzano does

not allege his sentence was unconstitutional, we review the legality of his

sentence for correction of errors at law. See State v. Zarate, 908 N.W.2d

831, 840 (Iowa 2018).

III. Analysis.

The sole issue is whether Lozano Campuzano’s minimum period of confinement is eligible for the one-half reduction provided by section

901.12. His minimum period of confinement is established by section

124.413(1), which states,

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