State of Iowa v. Brian Thomas Brandel

CourtCourt of Appeals of Iowa
DecidedApril 23, 2025
Docket24-1011
StatusPublished

This text of State of Iowa v. Brian Thomas Brandel (State of Iowa v. Brian Thomas Brandel) 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. Brian Thomas Brandel, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1011 Filed April 23, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

BRIAN THOMAS BRANDEL, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Dubuque County, Monica L. Ackley,

Judge.

A defendant appeals the revocation of his deferred judgment and sentence.

AFFIRMED.

Christopher C. Fry and Alyssa M. Carlson of O'Connor & Thomas, P.C.,

Dubuque, for appellant.

Brenna Bird, Attorney General, and Genevieve Reinkoester, Assistant

Attorney General, for appellee.

Considered without oral argument by Ahlers, P.J., and Badding and

Buller, JJ. 2

BADDING, Judge.

“Oh, what a tangled web we weave, when first we practice to deceive!”1 The

district court revoked Brian Brandel’s deferred judgment for first-degree fraudulent

practices and imposed a prison sentence after finding that Brandel had “outright

lied” to the court. Brandel appeals,2 claiming that the State failed to prove he

violated his probation and the court’s sentence was excessive. Finding no abuse

of the court’s discretion, we affirm.

During the COVID-19 pandemic, landlord Brian Brandel submitted

fraudulent applications to the Iowa Finance Authority for rental assistance funds.

Upon discovering Brandel’s fraud, the State charged him with first-degree

fraudulent practices. Brandel pled guilty to that charge in November 2023 and

agreed to repay the amount he had received—$15,467. If Brandel made the

payment before January 1, 2024, the State agreed to join in Brandel’s request for

a deferred judgment.

Brandel mailed a check for $15,467 by that deadline. So at his sentencing

hearing in late January, the State asked the district court to grant Brandel’s request

for a deferred judgment, noting: “The fact that he pled guilty and is willing to accept

the punishment says a lot just about his character. . . . Also very important is the

fact that he did repay our State back for the money that he got from filling out those

1 Sir Walter Scott, Marmion (1808). 2 State v. Thompson, 951 N.W.2d 1, 5 (Iowa 2020) (finding good cause to appeal

following guilty plea where defendant was challenging “the order revoking her deferred judgment and entering a judgment of conviction and sentence”). 3

applications.” The district court reluctantly went along with that recommendation,

telling Brandel:

I do think it was a very big hardship on landlord and tenant situations because of your inabilities, because people couldn’t go to work, people couldn’t pay you, and you’re the one standing there holding the bag. That is the only reason that I’m not putting you in prison. . . . The second reason, sub to that, is that you paid the money back.

But Brandel hadn’t actually paid the money back.

In May, the State applied to revoke Brandel’s deferred judgment when it

learned that his check for $15,467 “did not clear the bank.” Brandel claimed this

was accidental, asserting that he “had taken out a loan to pay the restitution

amount but the loan funds did not clear his bank” before the check was deposited.

That was a lie too. When Brandel’s bank records were subpoenaed, the State saw

that Brandel “never had sufficient funds in his account to cover the check for the

restitution.”

At the hearing on the State’s application, the prosecutor asked the court to

revoke his deferred [judgment]. I’m not going to ask to send him to prison, but I do think that the significant time that the Court has spent, that I’ve spent, this investigator has spent, because of his dishonesty, I think a significant fine, community service, I would ask for the maximum amount of formal probation for the 5 years, and him losing the deferred judgment.

In response, defense counsel stated that while Brandel did not contest the State’s

assertion that his first check was rejected, he wanted to provide context to show

“that he had no malicious intent.” Counsel explained,

Mr. Brandel is 56 years old. He has no prior criminal record and has prior to this no experience with the criminal justice system. When he pleaded guilty, he had the intent to mak[e] right and to fully comply with the plea agreement. . . . At the same time, Mr. Brandel was 4

experiencing a great deal of shame and anxiety. He was in a precarious financial position. When he sent the check, he had every intention of getting the money, but he was in a place where he could not tell somebody that he needed help. Mr. Brandel now realizes that he should have asked for help in the meantime. He has since made full restitution. . . .

Brandel accordingly asked the court to deny the State’s request to revoke his

deferred judgment and continue him on probation.

The district court declined to do so, ruling “the most important thing” it had

considered in granting Brandel a deferred judgment was

the fact that you were taking the brunt end of the problems with COVID and the fact that you . . . had paid the restitution. I said, “This is the only reason I’m not putting you in prison,” because normally, this is the type of offense where I think something needs to be set. You would have unfortunately been a person I set it for. .... I wasn’t going to give you a deferred in the first place. You would have been going to prison but for [the prosecutor] telling me that. . . . And you outright lied to me. . . . [Y]ou were deceitful when you filed the application, you were deceitful when you talked to me in the courtroom, you were deceitful when you negotiated with her to get this deal, and then you were further deceitful when you had your attorney relay information about a loan that didn’t exist.

With that explanation, the court revoked Brandel’s deferred judgment and imposed

an indeterminate prison sentence of ten years. We review those decisions for an

abuse of discretion. Thompson, 951 N.W.2d at 4 (“We will overturn a revocation

of probation only if there has been an abuse of discretion.”); State v. Headley, 926

N.W.2d 545, 549 (Iowa 2019) (applying an abuse of discretion standard when the

sentence challenged is within statutory limits).

Brandel first claims that because repayment of the $15,467 was not a

condition of his probation, the State failed to prove that he violated his probation.

See State v. Covel, 925 N.W.2d 183, 187 (Iowa 2019) (stating the first step in a 5

probation revocation “is determining whether the person has acted in violation of

one or more conditions of [their] probation”). We agree with the State that a similar

argument was rejected in State v. Brimacomb, where the district court granted the

defendant a deferred judgment after “relying on information which later proved to

be false”—the defendant’s eligibility for a deferred judgment. 474 N.W.2d 805,

805–06 (Iowa 1991). Our supreme court found the revocation “fit well within” the

district court’s authority under Iowa Code section 907.1 (2024),3 even though it had

“nothing to do with a program of probation,” because “orders to defer sentences

are interlocutory in nature and do not constitute final judgments.” Id. at 806. The

court also reasoned that the sentencing court’s “intent should be given substantial

deference.” Id.; see also State v. Darrin, 325 N.W.2d 110

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Related

State v. Boltz
542 N.W.2d 9 (Court of Appeals of Iowa, 1995)
State v. Darrin
325 N.W.2d 110 (Supreme Court of Iowa, 1982)
State v. Wright
340 N.W.2d 590 (Supreme Court of Iowa, 1983)
State v. Formaro
638 N.W.2d 720 (Supreme Court of Iowa, 2002)
State v. Brimacomb
474 N.W.2d 805 (Supreme Court of Iowa, 1991)
State of Iowa v. Christopher Ryan Covel
925 N.W.2d 183 (Supreme Court of Iowa, 2019)
State of Iowa v. Evan Paul Headley
926 N.W.2d 545 (Supreme Court of Iowa, 2019)

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State of Iowa v. Brian Thomas Brandel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-brian-thomas-brandel-iowactapp-2025.