State of Iowa v. Randol Andrew Garcia

CourtCourt of Appeals of Iowa
DecidedJanuary 9, 2025
Docket24-0141
StatusPublished

This text of State of Iowa v. Randol Andrew Garcia (State of Iowa v. Randol Andrew Garcia) 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. Randol Andrew Garcia, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0141 Filed January 9, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

RANDOL ANDREW GARCIA, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Cerro Gordo County,

Rustin T. Davenport, Judge.

A defendant appeals his sentence, alleging the district court abused its

discretion in failing to consider specific mitigating factors. AFFIRMED.

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

Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Timothy M. Hau, Assistant Attorney

General, for appellee.

Considered by Schumacher, P.J., and Badding and Chicchelly, JJ. 2

SCHUMACHER, Presiding Judge

Randol Garcia appeals his sentence, alleging that the district court abused

its discretion in sentencing him to a term of incarceration. Garcia, a juvenile at the

time of the commission of the offense, alleges the court failed to fully consider

mitigating factors when formulating his sentence. Upon our review, we affirm.

I. Background Facts and Proceedings

In June 2023, a juvenile court transport officer was driving Garcia to the

Eldora juvenile detention center. Garcia was handcuffed, and his legs were

shackled in the backseat of the vehicle. Enroute, Garcia asked the transport officer

to stop to use the restroom; his request was denied. Garcia then complained about

being ill. The driver pulled over to assist Garcia. Once the driver opened the door,

Garcia assaulted the driver. With the driver on the ground, Garcia took control of

the vehicle and drove from the scene. The transport driver had significant bleeding

from the head.1 Because the transport officer’s cellphone remained in the vehicle,

the location of the vehicle was traceable. Law enforcement initiated a pursuit.

Garcia lost control of the vehicle and was taken into custody.

Garcia was charged by trial information with first-degree robbery. He later

entered into a plea agreement which included a guilty plea to second-degree

robbery and an open sentence, with each side free to make sentencing

recommendations. The State recommended incarceration, while Garcia

requested a deferred judgment, or in the alternative, a suspended sentence and

1 Garcia stipulated to limited facts contained in the minutes of testimony as a basis

for his guilty plea. 3

probation.2 Following a hearing, which included arguments of counsel, a victim

impact statement, and a statement of allocution from Garcia, the district court

ordered Garcia to serve an indeterminate ten-year period of incarceration. The

court rejected the State’s request for a mandatory minimum period of incarceration,

and consequently, Garcia was immediately eligible for parole. Garcia appeals.3

II. Standard of Review

The sentence imposed is within the statutory limits. As such, we review for

an abuse of discretion. State v. Majors, 940 N.W.2d 372, 385 (Iowa 2020).

“Sentencing decisions of the district court are cloaked with a strong presumption

in their favor.” State v. Crooks, 911 N.W.2d 153, 171 (Iowa 2018). “[O]ur 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.” State v. Seats,

865 N.W.2d 545, 553 (Iowa 2015) (quoting State v. Formaro, 638 N.W.2d 720,

724–25 (Iowa 2002)). But we do not “rubber-stamp” the district court’s decision

2 Even though Garcia pleaded guilty to an offense defined as a forcible felony, see

Iowa Code § 702.11(1) (2023), because he was a juvenile at the time of committing the offense, he was eligible for a deferred judgment or a suspended sentence— sentencing options for which he would not be eligible had he been an adult at the time the crime was committed. Compare id. § 907.3 (making a defendant who has committed a forcible felony ineligible for a deferred judgment, deferred sentence, or suspended sentence), with id. § 901.5(13) (making a defendant eligible for a deferred judgment, deferred sentence, or suspended sentence if the defendant was under the age of eighteen at the time of the offense even if the defendant would be ineligible for such sentencing options if the offense were committed as an adult). 3 Because Garcia challenges only his sentence, he has established good cause to

appeal despite his guilty plea. See State v. Damme, 944 N.W.2d 98, 105 (Iowa 2020) (holding that good cause to appeal following a guilty plea within the context of Iowa Code section 814.6(1)(a)(3) exists “when the defendant challenges his or her sentence rather than the guilty plea”). 4

when imposing an adult sentence on a juvenile offender; even a discretionary

sentencing may be suspect if the court

fails to consider a relevant factor that should have received significant weight, gives significant weight to an improper or irrelevant factor, or considers only appropriate factors but nevertheless commits a clear error of judgment by arriving at a sentence that lies outside the limited range of choice dictated by the facts of the case.

State v. Roby, 897 N.W.2d 127, 138 (Iowa 2017) (citation omitted).

III. Analysis

Garcia argues the district court failed to consider mitigating factors including

his age and his features of youthful behavior, specifically, immaturity, impetuosity,

and failure to understand risks and consequences; the circumstances of the crime

relating to his youth that may have played a part; his family and home environment;

the trouble he may have in navigating the criminal justice system; and his possible

rehabilitation. As part of this argument, he alleges that the district court abused its

discretion by giving only “lip service” to the required sentencing factors and that it

placed too much emphasis on the nature of the crime and protection of the

community from the defendant.

With those challenges in mind, we look to the district court’s recitation at

Garcia’s sentencing hearing. After acknowledging review of the presentence

investigation report, the court stated, in relevant part:

In deciding the sentence, the Court considers the defendant’s age, attitude, prior criminal history, employment, financial and family circumstances, nature of the offense, use of weapon or force, the recommendation of the parties, and the ability to be rehabilitated through community services. We haven’t talked about the PSI, which recommended a suspended sentence with placement at a residential facility, another matter—another option that is before the Court. 5

My concern with the defendant’s proposal regarding a deferred judgment or suspended sentence, or even the PSI recommendation for place—for a suspended sentence with placement at a residential facility, is the Court’s concern regarding the possible danger of the defendant to others in the—in society. I—I appreciate Mr. Garcia’s comments that he has—has a realization that he cannot continue on his present path.

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Related

State v. Boltz
542 N.W.2d 9 (Court of Appeals of Iowa, 1995)
State v. Formaro
638 N.W.2d 720 (Supreme Court of Iowa, 2002)
State of Iowa v. Tina Lynn Thacker
862 N.W.2d 402 (Supreme Court of Iowa, 2015)
State of Iowa v. Damion John Seats
865 N.W.2d 545 (Supreme Court of Iowa, 2015)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
State of Iowa v. Christopher Ryan Lee Roby
897 N.W.2d 127 (Supreme Court of Iowa, 2017)
State of Iowa v. Noah Riley Crooks
911 N.W.2d 153 (Supreme Court of Iowa, 2018)
State v. Lyle
854 N.W.2d 378 (Supreme Court of Iowa, 2014)

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State of Iowa v. Randol Andrew Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-randol-andrew-garcia-iowactapp-2025.