State of Iowa v. Tyler Ward Patterson a/k/a Tyler Ward Shipley

• Court: Court of Appeals of Iowa
• Decided: December 3, 2025
• Docket: 25-0996
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-0996 Filed December 3, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

TYLER WARD PATTERSON a/k/a TYLER WARD SHIPLEY, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Marshall County, Adria Kester,

Judge.

A defendant appeals his sentence for first-degree theft. AFFIRMED.

Katherine R.J. Scott of New Point Law Firm, PLC, Ames, for appellant.

Brenna Bird, Attorney General, and Katherine Wenman, Assistant Attorney

General, for appellee.

Considered without oral argument by Chicchelly, P.J., and Buller and

Langholz, JJ. 2

LANGHOLZ, Judge.

While he was on probation for seven other offenses, Tyler Patterson wrote

checks for cash totaling more than $10,000—knowing that they would not clear—

and took money from the credit unions where he deposited the checks. He

eventually pleaded guilty to first-degree theft—a class “C” felony, see Iowa Code

§§ 714.1(6), 714.2(2) (2024)—and admitted to violating his probation in those

other cases as part of a global plea agreement. Patterson was thus facing a

potential total of twenty-seven years of consecutive prison sentences from the new

felony and the probation revocations.

The State argued for a total of twelve years in prison—a ten-year

indeterminate prison sentence on the new felony and another two consecutive

years on the probation revocations. Patterson argued that he should be placed on

probation again and ordered to complete inpatient treatment to address his mental-

health and substance-use issues. The district court agreed with the State that a

ten-year prison sentence was appropriate but declined to reimpose prison

sentences on the probation revocations—instead discharging him from probation

after holding him in contempt and sentencing him to time served.

Patterson appeals his sentence on the felony, arguing that the district court

did not adequately explain its reasons for the sentence and abused its discretion

in imposing the ten-year prison sentence rather than suspending it and placing him

on probation. We disagree. Because the district court adequately explained its

sentencing reasons and did not abuse its considerable sentencing discretion in

selecting the ten-year prison sentence, we affirm Patterson’s sentence. 3

I. Explaining the Reasons for the Sentence Imposed

Patterson first argues that the district court failed to adequately explain its

reasons for selecting his sentence. A sentencing “court shall state on the record

the basis for the sentence imposed.” Iowa R. Crim. P. 2.23(2)(g). This rule

“ensures defendants are well aware of the consequences of their criminal actions”

and “affords our appellate courts the opportunity to review the discretion of the

sentencing court.” State v. Luke, 4 N.W.3d 450, 456 (Iowa 2024) (cleaned up).

“[S]omething more specific” than “a boilerplate statement of reasons” is required.

Id. at 457 (cleaned up). But “a terse and succinct statement may be sufficient, so

long as the brevity of the court’s statement does not prevent review of the exercise

of the trial court’s sentencing discretion.” State v. Thacker, 862 N.W.2d 402, 408

(Iowa 2015) (cleaned up). Still, “the reasons for the exercise of discretion” must

be “obvious in light of the statement and the record before the court.” Id.

At sentencing, the district court gave an extensive explanation of the factors

it was considering in selecting the appropriate sentence—even questioning

Patterson on many factors to ensure that the court had an accurate understanding

and to highlight for him its reasoning. That included showing Patterson the literal

highlights the court made on his presentence investigation report recounting his

many convictions dating back to 1992 and confirming his agreement that at fifty-

one, he was “[c]ertainly old enough to know better.” The court explained:

I’m very, very cognizant and understanding about people that have mental health and substance abuse issues. . . . But that’s only one thing that I can consider. And when I consider all of those things that I just talked about, your age, your education, that whole list of things, on one hand, I’m super surprised that the State hasn’t asked for everything to run consecutively because they would certainly, with your criminal history and the interventions that have been made on 4

your behalf, that would be an appropriate recommendation, but they didn’t make that recommendation and so I’m not considering that.

And the court expressed its view that Patterson was “lucky I’m not sending you for

. . . 17 years just on your probation violations” and that he “dodged a bullet today.”

Still, it reasoned that it rejected the State’s higher recommendation of total

sentences because “I don’t know that 12 years is going to do you any better than

10 years. I just don’t think that was going to have any [e]ffect on you. If you really

mean it, you can get the help that you need.”

Contrary to Patterson’s argument on appeal, this explanation went “beyond

summarily listing” the factors it considers. The court provided case-specific

explanation. And in the total context of “the record before the court” and its

statements, it is “obvious” that the court found that some factors—such as

Patterson’s mental-health and substance-use issues and his remorse—weighed

against the State’s sentencing recommendation, while others—his extensive

criminal history and failure to take advantage of past interventions—weighed in

favor. Thacker, 862 N.W.2d at 408. Our review of the district court’s exercise of

its sentencing discretion is not hindered. So we reject Patterson’s challenge to the

adequacy of the court’s statement of reasons for the sentence imposed.

II. Selecting the Prison Sentence Rather than Probation

Patterson next argues that the court should have suspended his sentence

and placed him on probation rather than imposing a term of incarceration because

he “has significant mental health barriers,” “he needs ongoing treatment” and “his

responsibilities with respect to the justice system have impeded his ability to obtain

stability.” And he contends that the “clearly unreasonable” nature of the court’s 5

contrary conclusion is shown by the court’s decision in another case two years

before to place him on probation.

We review a district court’s discretionary selection of a sentence, including

its exercise of discretion whether to suspend a sentence, for an abuse of

discretion. See State v. Formaro, 638 N.W.2d 720, 724 (Iowa 2002). This

deferential standard of review recognizes that the court’s decision “to impose a

particular sentence within the statutory limits is cloaked with a strong presumption

in its favor.” Id. And even when the court would have been justified in imposing

the sentence the defendant sought, “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. at 725.

The district court expressly considered the mental-health and substance-

use issues that Patterson relies on and discussed its prior sentencing decision.

But it properly reasoned that they were not the only factors it could consider. And

in weighing all the factors, the court concluded that his extensive criminal history

and failure to take advantage of the past interventions while on probation

counseled in favor of imposing a prison sentence rather than probation again. We

do not see any unreasonable or untenable grounds in the court’s reasoning.

At bottom, Patterson asks us to weigh the sentencing factors differently to

conclude that a suspended sentence was appropriate. But that is not the issue we

decide on appeal. See State v. Gordon, 998 N.W.2d 859, 863 (Iowa 2024). And

so, the district court did not abuse its discretion in exercising its sentencing

judgment. We thus affirm Patterson’s sentence.

AFFIRMED.