State of Iowa v. Brian Thomas Woods
This text of State of Iowa v. Brian Thomas Woods (State of Iowa v. Brian Thomas Woods) 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.
Opinion
IN THE COURT OF APPEALS OF IOWA
No. 24-0412 Filed August 7, 2024
STATE OF IOWA, Plaintiff-Appellee,
vs.
BRIAN THOMAS WOODS, Defendant-Appellant. ________________________________________________________________
Appeal from the Iowa District Court for Dubuque County, Robert J. Richter,
Judge.
A defendant appeals his criminal sentences. AFFIRMED.
Gregory F. Greiner, West Des Moines, for appellant.
Brenna Bird, Attorney General, and Joseph D. Ferrentino, Assistant
Attorney General, for appellee.
Considered by Tabor, P.J., Schumacher, J., and Mullins, S.J.*
*Senior judge assigned by order pursuant to Iowa Code section 602.9206
(2024). 2
MULLINS, Senior Judge.
Brian Woods pled guilty in three separate cases to interference with official
acts while displaying a dangerous weapon, assault while displaying a dangerous
weapon, assault with intent to inflict serious injury, and assault causing bodily
injury. At the sentencing hearing encompassing all cases, the district court
summarily sentenced him in accordance with the terms of the universal plea
agreement, which included the foregoing charges being served concurrently with
one another but consecutive to the sentence imposed in a separate case.
Woods appeals. While he agrees “that the district court did not depart from
the terms of the plea agreement,” he argues the district “court erred by not stating
on the record nor its sentencing orders the reasons for selecting a particular
sentence,” which “makes it impossible to assess whether there was an abuse of
discretion in sentencing him to a consecutive sentence.” But each of the three
sentencing orders noted the nature and circumstances of the crimes as well as the
plea agreement as the reasons for imposing the consecutive portion of the
sentences. See, e.g., State v. Eaton, No. 01-2024, 2002 WL 1842923, at *1 (Iowa
Ct. App. Aug. 14, 2002) (finding “the nature of the crime” was a sufficient reason
for imposing a consecutive sentence). Even if it hadn’t, a statement of reasons for
selecting a particular sentence is not required when it is “not the product of the
exercise of trial court discretion but of the process of giving effect to the parties’
agreement.” State v. Thacker, 862 N.W.2d 402, 408 (Iowa 2015) (quoting State v.
Snyder, 336 N.W.2d 728, 729 (Iowa 1983)); accord State v. Wilbourn, 974
N.W.2d 58, 68 (Iowa 2022) (“It is not an abuse of discretion for the court to impose
a sentence consistent with the parties’ plea agreement without giving additional 3
reasons for rejecting other sentencing options.”); State v. Cason, 532
N.W.2d 755, 756 (Iowa 1995) (per curiam) (noting a statement of “reasons for
imposition of sentence would serve no useful purpose” where the parties “have
approved a plea agreement and the sentencing court incorporates the plea
agreement in the sentence”).
Here, the district court provided sufficient reasons for imposing the
consecutive portion of the sentences. Even if it hadn’t, it wasn’t required to. We
affirm without further opinion pursuant to Iowa Court Rule 21.26(1)(a), (c), and (e).
AFFIRMED.
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