State of Iowa v. Keith Williams
This text of State of Iowa v. Keith Williams (State of Iowa v. Keith Williams) 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. 23-1258 Filed December 4, 2024
STATE OF IOWA, Plaintiff-Appellee,
vs.
KEITH WILLIAMS, Defendant-Appellant. ________________________________________________________________
Appeal from the Iowa District Court for Polk County, Michael D. Huppert,
Judge.
A defendant who pled guilty appeals the district court’s imposition of a
sentence provided for in a plea agreement. APPEAL DISMISSED.
Jessica Donels of Parrish Kruidenier, L.L.P., Des Moines, for appellant.
Brenna Bird, Attorney General, and Joshua A. Duden, Assistant Attorney
General, for appellee.
Considered by Schumacher, P.J., and Badding and Chicchelly, JJ. 2
SCHUMACHER, Presiding Judge.
Keith Williams appeals the sentence issued following his guilty pleas,
arguing the district court abused its discretion by failing to adequately explain its
reasons for imposing consecutive sentences and by failing to consider inpatient
addiction treatment as an alternative to incarceration. Because Williams has failed
to establish good cause to challenge his sentences, we dismiss his appeal.
I. Background Facts & Proceedings
Williams was charged by trial information in early 2023 with twelve criminal
violations. Pursuant to a plea agreement reached with the State, Williams pled
guilty to three charges: amended Count I, possession of heroin with intent to
deliver, a class “C” felony under Iowa Code section 124.401(1)(c)(1) (2023);
Count VII, failure to possess a tax stamp (heroin), a class “D” felony under sections
453B.3 and 453B.12; and Count XI, felon in possession of a firearm, a class “D”
felony under section 724.26. At the combined plea and sentencing hearing, the
parties jointly recommended the “counts would be run consecutive to each other
for a total period of incarceration not to exceed twenty years” and the State would
move to dismiss the remaining nine counts.
The district court then discussed sentencing with Williams:
[COURT] Q. Tell me what your understanding is of the sentencing that would be imposed if I accept that plea agreement. . . . . [WILLIAMS] A. My understanding is that it’s not to exceed twenty years. Q: Consecutive sentences totaling up to twenty years? A. Twenty years. Q. Yes. And go to prison? A. Yes. Q. Are you asking the Court to accept that agreement on those terms? A. Yes. Q. The Court will be accepting the plea agreement as stated by Counsel and confirmed by the defendant on the record such that 3
subject to my acceptance of Mr. Williams’[s] guilty plea here this afternoon, any sentence in this case will embody that agreement.
After accepting Williams’s plea, the district court announced Williams’s
sentences. The court stated:
The sentence for the offenses are as follows: As to Count I, an indeterminant period of incarceration not to exceed ten years, and as to Counts VII and XI, they are each punishable by up to five years in prison. You will receive credit against these sentences for time already served in custody on these offenses since your arrest. These sentences shall run consecutive to each other for a total period of incarceration not to exceed twenty years. Consecutive sentences are being imposed today due to the separate and serious nature of the offenses and as well as in order to carry out the plea agreement.
The written sentencing order accorded with the oral pronouncement. The trial
information’s remaining counts were dismissed.
Williams appeals. The State responds with a challenge to appellate
jurisdiction, arguing Williams failed to establish good cause.
II. Good Cause Under Iowa Code section 814.6
A defendant’s right to appeal is limited when their conviction resulted from
their own guilty plea. State v. Damme, 944 N.W.2d 98, 103 (Iowa 2020) (citing
Iowa Code § 814.6(1)(a)(3)). The right of appeal from a guilty plea only exists if a
guilty plea is to a class “A” felony or where a defendant establishes good cause.
§ 814.6(1)(a)(3). So when there is no conviction for a class “A” felony, “[a]
defendant who pled guilty now must establish good cause to appeal.” Damme,
944 N.W.2d at 104. Establishing good cause is the defendant’s burden. Id. When
a defendant fails to meet that burden, “the court has no jurisdiction, and the appeal
must be dismissed.” State v. Rutherford, 997 N.W.2d 142, 144 (Iowa 2023). 4
This good cause requirement arose from a legislative amendment that
became effective July 1, 2019. Damme, 944 N.W.2d at 103. The amendment was
made “to curtail frivolous appeals from guilty pleas and thereby enforce their
finality.” Id. at 100. The meaning of good cause as used in section 814.6(1)(a)(3)
is “a legally sufficient reason.” Id. at 104. Satisfaction of that requirement is
context specific and must “advance, rather than defeat, the purpose of the statute.”
Id. at 104–05 (quoting Rhoades v. State, 880 N.W.2d 431, 447 (Iowa 2016)).
Our supreme court previously said in Damme, “good cause exists to appeal
from a conviction following a guilty plea when the defendant challenges his or her
sentence rather than the guilty plea.” Id. at 105. But Damme does not rule that
good cause is inherent to any challenged post-plea sentence. The Damme court
held that in the context of an appellate challenge to a post-guilty plea sentencing
order, a defendant establishes good cause “when the defendant appeals a
sentence that was neither mandatory nor agreed to in the plea bargain.” Damme,
944 N.W.2d at 100. It remains undecided by our supreme court whether good
cause exists to appeal a sentence conforming to the bounds of a plea agreement.
State v. Wilbourn, 974 N.W.2d 58, 66 (Iowa 2022) (saving that question “for
another day”).
The plea agreement included Williams’s consent to the consecutive
sentences totaling up to twenty years. The record shows the court adopted the
parties’ jointly recommended sentence. Williams does not claim the district court
imposed a sentence beyond that contemplated by the agreement. His challenge
is to the reasoning behind the district court’s adoption of the consensual sentence; 5
that argument does not establish good cause. And, unlike in Wilbourn, Williams
alleges no other sentencing error outside the scope of the plea agreement.
Because Williams received the agreed-upon sentence under the plea
agreement, he has not established good cause to appeal. See State v. Thompson,
951 N.W.2d 1, 2 (Iowa 2020) (“[A] defendant who is not challenging her guilty plea
or conviction has good cause to appeal an alleged sentencing error when the
sentence was neither mandatory nor agreed to in the plea bargain.”); State v.
Estabrook, No. 22-1118, 2023 WL 2671954, at *1 (Iowa Ct. App. Mar. 29, 2023)
(collecting cases that dismissed appeals “due to lack of showing of good cause
when the sentence imposed is mandatory or the agreed-upon sentence under the
plea agreement”). Without good cause, we have “no jurisdiction, and the appeal
must be dismissed.” Rutherford, 997 N.W.2d at 144.
III. Conclusion
Because Williams failed to establish good cause, we dismiss his appeal.
APPEAL DISMISSED.
Free access — add to your briefcase to read the full text and ask questions with AI
Related
Cite This Page — Counsel Stack
State of Iowa v. Keith Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-keith-williams-iowactapp-2024.