State of Iowa v. Joshua Allen Hubler

CourtCourt of Appeals of Iowa
DecidedMarch 19, 2025
Docket24-0631
StatusPublished

This text of State of Iowa v. Joshua Allen Hubler (State of Iowa v. Joshua Allen Hubler) 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. Joshua Allen Hubler, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0631 Filed March 19, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

JOSHUA ALLEN HUBLER, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Cedar County, Stuart P. Werling,

Judge.

A defendant appeals his prison sentence for possession of

methamphetamine with intent to deliver. SENTENCE VACATED AND

REMANDED FOR RESENTENCING.

Martha J. Lucey, State Appellate Defender, and Theresa R. Wilson,

Assistant Appellate Defender, for appellant.

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

General, for appellee.

Considered by Tabor, C.J., and Ahlers and Sandy, JJ. 2

TABOR, Chief Judge.

Finding that Joshua Hubler had “not benefited from the treatment options in

the community that have been made available to him so far,” the district court

sentenced him to an indeterminate ten-year prison sentence for a

methamphetamine offense. Trouble is, nothing in the record shows that Hubler

had been offered or participated in substance-use treatment in the community.

Because the court’s incarceration decision was driven by its misreading of the

record, we vacate Hubler’s sentence and remand for resentencing.

I. Facts and Prior Proceedings

The State charged Hubler with twelve counts of drug-related crimes

stemming from a December 2022 traffic stop. Eleven months later, Hubler reached

a plea agreement with the prosecution. He pleaded guilty to possession with intent

to deliver less than five grams of methamphetamine, a class “C” felony, in violation

of Iowa Code section 124.401(1)(c)(6) (2022). In return, the State dismissed the

remaining charges. Under their agreement, the State would recommend “10 years

in prison,” while Hubler could request “a more lenient disposition.” The district

court ordered the preparation of a presentence investigation report (PSI).

At the sentencing hearing, the county attorney highlighted Hubler’s criminal

history in recommending incarceration. The county attorney also reminded the

court that Hubler had been rejected for placement at the district department of

correctional services Residential Corrections Facility (RCF). 1

1 The PSI tied that rejection to Hubler’s guilty plea to the class “C” felony, noting

“his actions carry a serious consequence and incarceration should be recommended.” As Hubler suggests on appeal, “it does not appear he was denied due to any particular concern about his amenability to treatment or supervision.” 3

By contrast, Hubler requested a suspended sentence with supervised

probation, pointing to his employment and his support in the community. Hubler

told the court that he was addicted to methamphetamine and “prison will not help

me with that. I do need inpatient therapy.”

The court then announced its sentencing decision:

As indicated by the parties, the defendant had been previously screened for placement at RCF and deemed ineligible for placement. That severely restricts the court’s ability to find and locate treatment options in the community. And the defendant, frankly, has not benefited from the treatment options in the community that have been made available to him so far. The court is drawn to the conclusion based on the recommendation of the PSI author and the PSI author recommends incarceration, the State recommends incarceration and the Court feels that is an appropriate sentencing option here based on the recommendation of the PSI author, the need to deter the defendant’s criminal activities and lack of other treatment options available in the community.

Hubler appeals his prison sentence. 2

II. Scope and Standard of Review

We review sentencing decisions for correction of legal error. State v.

McCollaugh, 5 N.W.3d 620, 627 (Iowa 2024). We presume sentences within

statutory limits are proper. Id. Given that strong presumption, we will not overturn

the sentencing court’s exercise of discretion unless Hubler can show an abuse of

that discretion or “consideration of inappropriate matters.” See id.

To earn a reversal, Hubler must show that the court relied on an improper

factor in choosing his sentence. See id. If he makes that showing, we won’t

After noting Hubler’s ineligibility for RCF, the PSI indeed recommended a prison term. 2 Hubler has good cause to appeal his prison sentence, which was neither agreed

to nor mandatory. See State v. Damme, 944 N.W.2d 98, 105 (Iowa 2020). 4

speculate about the weight assigned to that factor; we just vacate the sentence

and remand for resentencing. Id.

III. Analysis

Hubler contends that the district court abused its discretion by imposing a

prison sentence based on its “mistaken belief that [he] had received treatment”

before in the community without any benefit. Hubler also asserts—pointing to the

PSI—that he successfully completed probation in 2007 and 2021. On this record,

Hubler maintains that he deserves a new sentencing hearing free from that

mischaracterization of his treatment history.

On appeal, the State does not defend the accuracy of the court’s statements

that Hubler has received and failed to benefit from treatment options in the

community. The State concedes that nothing in the record shows Hubler has

engaged in substance-use treatment. Instead, the State tries to clean up the

court’s remarks, asserting “a contextual review of the record shows the court was

referring to Hubler’s poor performance on probation.” The State accuses Hubler

of making a “hyper-technical complaint that the court should have used a different

word—probation instead of treatment.” From there, the State insists that

“probation is a form of treatment for criminal offenders” and a “non-institutional

form of treatment . . . aimed at rehabilitation of the individual and prevention of

further criminal behavior.”3

3 Also on appeal, the State contradicts assertions from the county attorney at the sentencing hearing that Hubler was “successful on probation” after an operating- while-intoxicated conviction in 2021. The State now contends that the PSI shows Hubler was “unsuccessfully discharged” from probation in 2022. But the PSI does not include the word “unsuccessful” in describing Hubler’s 2022 discharge from 5

But when imposing a potentially decade-long prison sentence, words

matter. We cannot ignore the court’s erroneous references to treatment options

that were never “made available to” Hubler. Contrary to the State’s argument, it

does not appear that the district court was referencing Hubler’s “subpar

performance on probation” in choosing the prison sentence. The court never

uttered the word probation. True, the court did say it was “drawn to the conclusion”

that a prison sentence was appropriate based on the PSI recommendation. But

that recommendation did not rest on Hubler’s lack of success when granted

probation. At most, the PSI reported: “it appears he has had some difficulty in

adhering to the terms of his unsupervised probation.”4

Hubler acknowledges that his rejection for placement at the residential

facility “may well have limited the district court’s sentencing options.” But, as he

maintains, “a suspended sentence was still a viable option.” The district court

rejected that option based, at least in part, on the false premise that he had not

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State of Iowa v. Joshua Allen Hubler, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-joshua-allen-hubler-iowactapp-2025.