State of Iowa v. Tanner Allan Weitzel

CourtCourt of Appeals of Iowa
DecidedMay 13, 2026
Docket25-1346
StatusPublished

This text of State of Iowa v. Tanner Allan Weitzel (State of Iowa v. Tanner Allan Weitzel) 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. Tanner Allan Weitzel, (iowactapp 2026).

Opinion

IN THE COURT OF APPEALS OF IOWA _______________

No. 25-1346 Filed May 13, 2026 _______________

State of Iowa, Plaintiff–Appellee, v. Tanner Allan Weitzel, Defendant–Appellant. _______________

Appeal from the Iowa District Court for Boone County, The Honorable Ashley Sparks, Judge. _______________

AFFIRMED _______________

Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg, Assistant Appellate Defender, attorneys for appellant.

Brenna Bird, Attorney General, and Joshua Henry, Assistant Attorney General, attorneys for appellee. _______________

Considered without oral argument by Schumacher, P.J., Ahlers, J., and Bower, S.J. Opinion by Schumacher, P.J.

1 SCHUMACHER, Presiding Judge.

Tanner Weitzel appeals his sentence following a guilty plea to robbery in the first degree in violation of Iowa Code sections 711.1(1) and 711.2 (2025), alleging the district court abused its discretion in sentencing him to an indeterminate term of incarceration not to exceed twenty-five years with a mandatory term of eight years. Upon our review, we affirm.

I. Background Facts & Proceedings

Weitzel was charged with first-degree robbery, second-degree kidnapping, and conspiracy to commit a forcible felony following an incident where he and accomplices assaulted an individual while armed with a firearm, intending to commit a theft. At the time of the incident, Weitzel was seventeen years and eight months old. Weitzel entered into a plea agreement with the State wherein he agreed to plead guilty to first-degree robbery in exchange for the State’s dismissal of the two remaining counts. The district court accepted Weitzel’s plea and ordered the preparation of a presentence investigation (PSI). The PSI recommended incarceration. Prior to sentencing, Weitzel was evaluated by separate psychologists, one hired by the State and one hired by the defense. Both psychologists testified at the sentencing hearing. The State’s psychologist, Dr. Lestina, recommended incarceration followed by probation and inpatient substance- use treatment. The defense psychologist, Dr. Nesbit, recommended probation and participation in a community treatment program.

Following a detailed explanation of relevant sentencing factors, the district court sentenced Weitzel to an indeterminate term of incarceration not to exceed twenty-five years, with a mandatory minimum of eight years of

2 incarceration prior to Weitzel being eligible for parole. Weitzel appeals his sentence.

II. Analysis

Weitzel’s appeal focuses on his age at the time of the commitment of the offense and the district court’s application of the specialized standards the court uses when sentencing a juvenile offender. Weitzel asserts the district court abused its discretion when utilizing the required Lyle factors because it found some of the factors non-mitigating. See State v. Lyle, 854 N.W.2d 378, 404 n.10 (Iowa 2014). The State counters that while the court is required to consider the Lyle factors, it is not mandatory to treat them as mitigating.

We review sentencing challenges for an abuse of discretion. State v. Gordon, 998 N.W.2d 859, 862 (Iowa 2023). A sentencing court abuses its discretion when it relies on inappropriate factors or “when the sentence is based on grounds that were clearly untenable or unreasonable.” Id. “We presume that a sentence within the statutory limits is valid . . . .” Id. When sentencing a juvenile, the court may abuse its discretion “when [it] fails to consider the appropriate sentencing factors, inappropriately weighs these factors, or 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. Miller, 16 N.W.3d 663, 672 (Iowa 2024) (cleaned up).

When a sentencing court considers imposing a mandatory period of incarceration for a juvenile offender, it must utilize the Lyle factors to determine if such a sentence is warranted. Id. at 673. These include: (1) the age of the offender and the features of youthful behavior, such as “immaturity, impetuosity, and failure to appreciate risks and consequences”; (2) the particular “family and home environment” that

3 surround the youth; (3) the circumstances of the particular crime and all circumstances relating to youth that may have played a role in the commission of the crime; (4) the challenges for youthful offenders in navigating through the criminal process; and (5) the possibility of rehabilitation and the capacity for change.

Id. at 673–74 (citation omitted). We will affirm the district court if the sentencing hearing is individualized, the court considers the Lyle factors, and the sentence imposed is supported by the evidence and authorized by statute. State v. Majors, 940 N.W.2d 372, 387 (Iowa 2020).

The crux of Weitzel’s argument is that the district court abused its discretion by not treating each Lyle factor as mitigating. We disagree with this argument. Our court has recently explained: [W]e do not believe . . . the district court is specifically required to find each of the Lyle factors to be mitigating. Such a blanket requirement would be incompatible with the goal of utilizing the Lyle factors, which is to conduct an individualized assessment of a juvenile offender to aid in reaching an appropriate sentence.

State v. Sanchez, No. 24-0157, 2025 WL 548326, at *6 (Iowa Ct. App. Feb. 19, 2025). Our appellate courts have repeatedly upheld sentencing court’s determinations of whether a Lyle factor is mitigating or aggravating. See Miller, 16 N.W.3d at 681–83; Majors, 940 N.W.2d at 388–91; State v. Meredith, No. 23-1372, 2024 WL 4370050, at *6–8 (Iowa Ct. App. Oct. 2, 2024).

We turn to Weitzel’s arguments that the district court abused its discretion in applying the Lyle factors. For the purposes of review, we focus on the factors that the court found were not mitigating. For the first factor, the district court reasoned: The first of those factors is the age and the features of your youth, including things like immaturity and impetuosity and failure to appreciate the risk and consequences of your actions.

4 Specifically, you were just under the age of eighteen when this crime was committed. The Court noted obviously that [Dr.] Nesbit, especially, testified that brains don’t fully develop until we are into our early or mid-twenties, specifically our frontal lobe that helps with things like addiction and planning, understanding our consequences, having insight to how our actions might impact others.

So it is safe to say that your brain was not fully developed based on your age; however, you are also at the older end of that spectrum. We are not looking at someone who is twelve or thirteen who committed this offense. We are looking at someone who was on the higher end of that.

We also have significant testing that was offered, both in Dr. Lestina and Dr. Nesbit’s reports, which generally say that you are personable, you are able to understand right from wrong, you have some insight as to how your actions have impacted others . . . and also have an understanding, potentially, about your substance abuse or how that has impacted your decision-making ability.

....

[Y]ou have significant substance abuse problems for your age . . . . There is no doubt in my mind that has likely impacted your brain development.

On sort of the flip side of that, you did score highly, or at least average, on some of those functioning skills. You have finished high school. So the Court isn’t viewing some of those complexities with age as a number as being a mitigating factor for you . . . . The Court does not view that factor as being mitigating.

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Related

State of Iowa v. Christopher Ryan Lee Roby
897 N.W.2d 127 (Supreme Court of Iowa, 2017)
State v. Lyle
854 N.W.2d 378 (Supreme Court of Iowa, 2014)

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State of Iowa v. Tanner Allan Weitzel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-tanner-allan-weitzel-iowactapp-2026.