State of Iowa v. Demetrias Alan Martin

CourtSupreme Court of Iowa
DecidedJanuary 26, 2024
Docket21-0102
StatusPublished

This text of State of Iowa v. Demetrias Alan Martin (State of Iowa v. Demetrias Alan Martin) 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.

Bluebook
State of Iowa v. Demetrias Alan Martin, (iowa 2024).

Opinion

IN THE SUPREME COURT OF IOWA

No.21–0102

Submitted September 13, 2023—Filed January 26, 2024

STATE OF IOWA,

Appellee,

vs.

DEMETRIAS MARTIN,

Appellant.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Scott County, Tamra Roberts,

Judge.

A defendant appeals the mandatory minimum term imposed with his

sentence for first-degree robbery. DECISION OF COURT OF APPEALS AND

DISTRICT COURT JUDGMENT AFFIRMED. McDermott, J., delivered the opinion of the court, in which all justices

joined. Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg,

Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Darrel Mullins, Assistant Attorney

General, for appellee. 2

MCDERMOTT, Justice. Demetrias Martin was convicted of first-degree robbery. At his sentencing

hearing, the district court considered results from an assessment tool designed

to estimate Martin’s risk of reoffending. That tool, the Iowa Risk Assessment

Revised, indicated that Martin scored as “high” risk for violent recidivism and

“moderate/high” risk for continuous victimization, resulting in an assigned

recommended level of correctional supervision of “intensive.” Martin argues that

the district court’s reliance on these conclusions from the risk assessment,

without any information about how the tool actually arrived at them, was an

abuse of discretion.

I.

In March 2019, Martin was sentenced to twenty-five years in prison with

a requirement to serve at least 70% of his sentence under a statutory mandatory

minimum. Martin appealed, challenging this conviction and sentence on several

grounds. The court of appeals affirmed his conviction. But because of a retroac-

tive amendment to the robbery sentencing statute passed in June 2019, it de-

termined that Martin was eligible for resentencing with a potential mandatory

minimum as low as 50%. See 2019 Iowa Acts ch. 140, § 8 (codified at Iowa Code § 902.12(3) (2020)).

The amendment to the sentencing statute added factors for the district

court to consider when determining the mandatory minimum to impose: “all per-

tinent information including the person’s criminal record, a validated risk as-

sessment, and the negative impact the offense has had on the victim or other

persons.” Iowa Code § 901.11(3) (2020). After the court remanded for resentenc-

ing, the State filed a motion requesting that the department of correctional ser-

vices prepare an addendum to Martin’s presentence investigation report to in- clude a validated risk assessment since one had not been required when Martin 3

was originally sentenced. The district court granted the motion and ordered an

addendum to include a “Validated Risk Assessment pursuant to Iowa Code Sec-

tion 901.11(3).”

An updated presentence investigation report filed about three weeks later

included the following paragraph under the heading “Addendum Update”:

On November 03, 2020, [t]he defendant was assessed utilizing the Iowa Risk Assessment Revised. The Iowa Risk Assessment Revised is a brief actuarial instrument used to estimate offenders’ level of risks associated with them violently reoffending and their continu- ous victimization. The defendant is noted to have scored a High risk for violent recidivism, and a Moderate/High risk for continuous vic- timization, with an Intensive level of recommended correctional su- pervision.

At the sentencing hearing two months later, Martin’s lawyer made several

statements about this risk assessment information. He conceded that “the stat-

ute tells the Court that they can take it into consideration.” But he argued

against the district court’s consideration of the risk assessment because he

lacked information about how the assessment tool arrived at the proffered con-

clusions. He stated:

I don’t think that the way our Seventh Judicial District does the Risk Assessment really qualifies as providing my client with any due process. Just because it’s statutorily authorized doesn’t mean that it’s, necessarily, the way it’s being used, appropriate.

. . . [W]hen we’re talking about sentencing, . . . the defend- ant . . . has the right to be sentenced based upon accurate infor- mation and he has the right to challenge facts and circumstances that might impact his sentencing.

You know, what we have here is just a conclusory state- ment, just that he’s high risk. I don’t have the ability to cross- examine anybody as to why that is, what criteria were used, or standard, or questions, . . . what answers were given, whether it was norm to local populations. I don’t have any way to respond to that at all. It’s just a conclusory statement, and I don’t feel that it’s fair for that to be considered. 4

. . . And so I raise the objection to using that simply because I think to do my duty and to be an effective defense attorney I have to point out that I don’t have any way to challenge that, and it appears to be a big part of what the Court might consider. . . . [I]t’s unfair to use that to determine . . . the length of the sentence . . . because I don’t know what -- what went into it.

Neither Martin nor the State presented any evidence at the sentencing

hearing. Martin argued for the 50% mandatory minimum. The State again ar-

gued for the 70% mandatory minimum.

In explaining its sentencing decision, the district court noted that it had

reviewed the presentence investigation report and the risk assessment adden-

dum. The district court described how it would treat the risk assessment:

I understand the factors that [Martin’s lawyer] has pointed out. And the Court can only weigh the Validated Risk Assessment minimally because the Court doesn’t have the factors on which that assess- ment has relied either to make [its] own determination of whether or not that’s appropriate. However, I have taken it into consideration, as required by the code, but I don’t think that I’m weighing it heavily by any means since I don’t know what factors it relied on either, other than what’s, I guess, in the instrument that they use.

The district court explained that “the bulk of the reason” for the sentence it would

impose on Martin—twenty-five years with the same 70% mandatory minimum

as before—centered on his crime’s negative impact on the victim and the com- munity.

Martin appealed the district court’s sentence. We transferred the case to

the court of appeals, which affirmed the sentence. We granted Martin’s request

for further review.

II.

Iowa Code § 901.11(3) specifies several factors that the district court must

consider when sentencing a defendant for robbery:

At the time of sentencing, the court shall determine when a person convicted of robbery in the first degree . . . shall first become eligible for parole . . . based upon all pertinent information including the 5

person’s criminal record, a validated risk assessment, and the neg- ative impact the offense has had on the victim or other persons.

Martin argues on appeal that despite a lack of evidence that the risk as-

sessment had been “validated,” the district court nonetheless considered it based

on an erroneous belief that it had to consider it.

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State v. Ashley
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926 N.W.2d 545 (Supreme Court of Iowa, 2019)

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State of Iowa v. Demetrias Alan Martin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-demetrias-alan-martin-iowa-2024.