State of Iowa v. Aaron Paul Woodman

CourtCourt of Appeals of Iowa
DecidedApril 23, 2025
Docket24-0177
StatusPublished

This text of State of Iowa v. Aaron Paul Woodman (State of Iowa v. Aaron Paul Woodman) 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
State of Iowa v. Aaron Paul Woodman, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0177 Filed April 23, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

AARON PAUL WOODMAN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Carroll County, Joseph McCarville,

Judge.

Aaron Paul Woodman appeals the sentences imposed by the district court

after pleading guilty to two counts of forgery. AFFIRMED.

Leah Patton of Patton Legal Services, LLC, Ames, for appellant.

Brenna Bird, Attorney General, and Joshua Henry, Assistant Attorney

General, for appellee.

Considered without oral argument by Tabor, C.J., and Schumacher and

Chicchelly, JJ. 2

CHICCHELLY, Judge.

Aaron Paul Woodman appeals the sentences imposed by the district court

after pleading guilty to two counts of forgery.1 Because the court did not abuse its

discretion when sentencing him, we affirm Woodman’s sentences.

After Woodman used forged checks and a stolen credit card to make

purchases, the State charged him with two counts of forgery, one count of credit

card fraud, and one count of third-degree theft. Pursuant to a plea agreement,

Woodman pled guilty to the two forgery counts. The court accepted his plea,

ordered a presentence investigation (PSI), and dismissed the remaining counts.

Sentencing was initially scheduled for October 2023. But the hearing was

delayed for several months because Woodman absconded from custody and

refused to cooperate with the PSI investigator. In mid-November, the court issued

a bench warrant, and Woodman was arrested in December. On December 27, the

sentencing hearing finally occurred, at which the court requested a status update

on Woodman’s pending charges in other counties. In response, Woodman’s

counsel stated “this is the last county for sentencing. All of the other counties have

been resolved and [Woodman was] sentenced . . . to probation on all of them.”

Sentencing then proceeded, with the State asking the court to adopt the PSI’s

recommendation for incarceration and Woodman requesting probation. The court

1 Generally, defendants do not have a right to appeal after pleading guilty unless

they establish good cause. See Iowa Code § 814.6(1)(a)(3) (2023). But because Woodman is challenging the discretionary sentence imposed on his conviction rather than the plea itself, he has good cause to pursue this appeal. See State v. Damme, 944 N.W.2d 98, 105 (Iowa 2020). 3

sentenced Woodman to an indeterminate term of incarceration not to exceed five

years. He appeals.

Woodman alleges that the court abused its discretion by considering

pending charges, failing to consider certain mitigating factors, and failing to

exercise its discretion. We review sentencing decisions for correction of errors at

law. Damme, 944 N.W.2d at 103. “A sentencing court’s decision to impose a

specific sentence that falls within the statutory limits ‘is cloaked with a strong

presumption in its favor, and will only be overturned for an abuse of discretion or

the consideration of inappropriate matters.’” Id. at 105–06 (citation omitted). An

abuse of discretion occurs when the sentencing decision “was exercised on

grounds or for reasons that were clearly untenable or unreasonable.” Id. at 106

(citation omitted).

Woodman first contends that the court improperly considered pending

charges.2 “[A] sentencing court cannot consider unproven or unprosecuted

offenses in fashioning a defendant’s sentence unless the defendant admits them

or facts are presented to prove them.” State v. Fetner, 959 N.W.2d 129, 135

(Iowa 2021). However, Woodman and his counsel represented to the court that

there were no pending charges; they had all “been resolved” and resulted in

2 The pending charges were included in the PSI report and discussed by the parties

at the sentencing hearing. To the extent that Woodman challenges the PSI report itself, because he did not object to the report at sentencing, he did not preserve error. See State v. Schooley, 13 N.W.3d 608, 617 (Iowa 2024) (permitting the court “to consider portions of a PSI that are not challenged by the defendant” (cleaned up)). But we do not require defendants to make such an objection when the court relies on unproven offenses. See id. at 618. To the extent that he argues that the court improperly considered the unproven offenses, we proceed to the merits. 4

probation. While Woodman remained silent during this exchange, he did not

challenge the alleged facts either. See id. at 135 (finding defendant’s failure to

challenge counsel’s recitation “amounted to an admission by acquiescence to the

facts”). Further, these charges were noted in the PSI which Woodman agreed to

the court using, without correction or change, for purposes of his sentencing.

Moreover, Woodman provides no evidence that the court even considered the

charges to determine the appropriate sentence. See State v. McCollaugh,

5 N.W.3d 620, 627 (Iowa 2024) (“To establish reversible error based on an

improper sentencing factor, the defendant is required to show that the court was

not just merely aware of the fact, but that it relied on the factor in determining its

sentence.” (emphasis added)). The court did not reference the charges when it

detailed its reasons for the sentence, and Woodman does not offer any evidence

that the court relied on them. See id. at 628 (considering whether the court

expressly mentions the alleged improper factor during its sentencing explanation).

We therefore do not find any merit in Woodman’s argument.

Woodman next cites several mitigating factors, such as his history of sexual

assault while incarcerated and his mental-health diagnoses, which he claims

required the court to consider probation.3 While the court was not “required to

specifically acknowledge each claim of mitigation urged by a defendant,” see State

v. Boltz, 542 N.W.2d 9, 11 (Iowa Ct. App. 1995), the court here did. At the hearing,

3 Woodman also argues that because he received probation for similar charges in

other counties, the court should have sentenced him to probation here. But we do not find this factor to be mitigating at all. See Damme, 944 N.W.2d at 107 (categorizing the defendant’s repetitive criminal history as aggravating). In fact, the court considered Woodman’s extensive criminal history, often for the same or similar crimes, when it determined he likely would not succeed on probation. 5

Woodman expressed fear that he would be sexually assaulted again while in

prison and explained the impact this had on his mental health. While the court

listened to Woodman’s concerns and showed empathy, it also weighed this against

Woodman’s lengthy, repetitive criminal history and the need to protect the public.

The court also correctly noted that it couldn’t “consider bad behavior of others” to

determine Woodman’s sentence because the sentencing factors are individualized

to each defendant. See Iowa Code § 907.5 (setting out specific factors for the

court to consider before suspending sentence). While the sentence imposed by

the court is not what Woodman wanted, “this does not mean the choice of one

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Related

State v. Boltz
542 N.W.2d 9 (Court of Appeals of Iowa, 1995)
State v. Formaro
638 N.W.2d 720 (Supreme Court of Iowa, 2002)

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State of Iowa v. Aaron Paul Woodman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-aaron-paul-woodman-iowactapp-2025.