State of Iowa v. Kevin Jerome Arnold

CourtCourt of Appeals of Iowa
DecidedOctober 6, 2021
Docket20-0915
StatusPublished

This text of State of Iowa v. Kevin Jerome Arnold (State of Iowa v. Kevin Jerome Arnold) 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. Kevin Jerome Arnold, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0915 Filed October 6, 2021

STATE OF IOWA, Plaintiff-Appellee,

vs.

KEVIN JEROME ARNOLD, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Joel Dalrymple,

Judge.

The defendant appeals the district court’s denial of a motion for discharge

from probation. REVERSED AND REMANDED.

Martha J. Lucey, State Appellate Defender, and Melinda J. Nye, Assistant

Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Zachary Miller, Assistant Attorney

General, for appellee.

Heard by Greer, P.J., Badding, J., and Doyle, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2021). 2

BADDING, Judge.

The novel issue presented in this appeal is whether the district court abused

its discretion in denying Kevin Arnold’s motion to discharge his probation ten years

after the period of probation expired. Because we find the district court failed to

exercise its discretion in summarily denying the motion, we reverse and remand

for further proceedings.

I. Background Facts and Proceedings

On January 20, 2005, Kevin Arnold was convicted of three counts of credit

card forgery, one of which was a felony. He received suspended prison sentences

and was placed on probation to the department of correctional services for two to

five years. In a different case, Arnold was convicted of child endangerment on

March 18, 2005. He again received a suspended prison sentence and was placed

on probation for two years.

A report of violation was filed in both cases in September 2005 and arrest

warrants were issued. Upon return of the warrants, Arnold’s probation was

modified to require him to remain at a residential correctional facility until maximum

benefits were received. He was discharged from the facility in January 2006.

In April 2006, Arnold’s probation officer filed another report of violation in

both cases. Arrest warrants were issued the same day the report was filed.

Nothing further happened in either case until May 2020 when Arnold entered into

a payment plan with the county attorney’s office for outstanding court debt.

After doing so, Arnold filed a motion for discharge from probation. He

argued that because 3

no application for revocation of Defendant’s probation has ever been filed by the State prior to its expiration, and a payment plan has been established with the county attorney for the unpaid court debt, Defendant is unequivocally entitled to the order of discharge that he seeks in this motion. In addition, in light of the foregoing, it is further requested that the outstanding arrest warrants be recalled and quashed forthwith.

The district court summarily denied the motion.

Arnold sought discretionary review of this ruling. The State filed a

resistance, following which the Iowa Supreme Court entered an order finding

Arnold has a right to appeal pursuant to State v. Pierce, No. 07-0496, 2008 WL

2039314, at *1 (Iowa Ct. App. May 14, 2008) and treating the application for

discretionary review as a notice of appeal. See Iowa R. App. P. 6.703(2)(a)(2).

On appeal, Arnold characterizes his motion for discharge from probation as

a challenge to an illegal sentence. He argues that “after the term of probation has

expired, the court has no authority to extend the probation—the court must

discharge the person from probation.” By failing to do so, Arnold contends the

court “effectively extend[ed] his probation indefinitely.” Arnold also raises a due

process claim, asserting the “State’s nearly fifteen-year-delay in prosecuting

Arnold’s alleged probation violation and executing the arrest warrant—continuing

Arnold’s probation ten years past its expiration—is a violation of Arnold’s due

process rights.” In the alternative, Arnold argues “it was an abuse of discretion to

summarily deny Arnold’s motion under the circumstances.”

The State initially responds by questioning the district court’s jurisdiction to

address the motion for discharge. The State’s main argument, however, is that

discharge from probation is not mandatory as Arnold suggests and that

“[p]ractically speaking, the defendant is no longer on probation so a discharge 4

order was unnecessary.” The State finally argues that Arnold failed to preserve

error on his due process claim, which it contends fails on its merits because

Arnold’s probation was not extended by the district court’s denial of his motion.

II. Scope and Standards of Review

The parties agree that a defendant’s sentence is reviewed for the correction

of errors at law, while challenges to specific probation conditions, probation

duration, or a request to be discharged from probation are reviewed for an abuse

of discretion. Pierce, 2008 WL 2039314, at *2. “The district court has broad

discretion in probation matters and ‘our task on appeal is not to second guess the

decision made by the district court, but to determine if it was unreasonable or

based on untenable grounds.’” Id. (quoting State v. Valin, 724 N.W.2d 440, 445

(Iowa 2006)). Our review of alleged violations of constitutional rights is de novo.

Barker v. State, 479 N.W.2d 275, 278 (Iowa 1991).

III. Analysis

A. Jurisdiction

Before addressing the merits of Arnold’s claims, we must first determine the

nature of our appellate jurisdiction. Arnold asserts the district court’s denial of his

motion for discharge from probation is equivalent to an indefinite extension of his

probation. Under the statutes in effect when Arnold’s crimes were committed,1 the

district court did not have the power to extend the period of probation once it was

1 The General Assembly has since amended Iowa Code sections 907.7(1), 908.11(4), and 910.4(1)(b) (2020) “to authorize courts expressly, in the event of probation violations, to ‘extend the term of probation for up to one year.’” Harris, 2010 WL 2925704, at *4 n.3 (quoting 2010 Iowa Acts ch. 1175). Those amendments, however, were not retrospective and apply only to criminal offenses committed on or after July 1, 2010. 5

set. State v. Harris, No. 09-1242, 2010 WL 2925704, at *3-4 (Iowa Ct. App. July

28, 2010); accord State v. Chase, 451 N.W.2d 493, 494-95 (Iowa 1990). Thus,

Arnold argues, his challenge to the district court’s order denying his motion to

discharge probation is a challenge to an illegal sentence. See State v. Lathrop,

781 N.W.2d 288, 293 (Iowa 2010) (“A challenge to an illegal sentence ‘includes

claims that the court lacked the power to impose the sentence or that the sentence

itself is somehow inherently legally flawed, including claims that the sentence is

outside the statutory bounds or that the sentence itself is unconstitutional.’”

(citation omitted)).

The State does not disagree with Arnold’s characterization of his appeal as

one challenging an illegal sentence but instead argues, contrary to the Iowa

Supreme Court’s order on the issue, that we do not have jurisdiction to consider

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Sullivan v. Chicago & Northwestern Transportation Co.
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State v. Wiederien
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State v. Pierce
752 N.W.2d 452 (Court of Appeals of Iowa, 2008)
State v. Hildebrand
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State v. Schweitzer
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State v. Chase
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State of Iowa v. Kevin Jerome Arnold, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-kevin-jerome-arnold-iowactapp-2021.