State v. Hill
Annotate this CaseDefendant pleaded guilty to failure to comply with sex-offender registry requirements. Defendant committed the offense while on parole for the underlying sex crime. The district court imposed a two-year prison sentence consecutive to Defendant’s parole revocation. Defendant appealed, arguing that the district court failed to provide adequate reasons for the consecutive sentence. A divided court of appeals affirmed the sentence, concluding that the presumption for consecutive sentences in Iowa Code 908.10A, the parole-revocation sentencing statute, excused the district court from the general requirement to state why it imposed a consecutive sentence. The Supreme Court reversed, holding (1) under section 908.10A, the district court must give reasons for imposing a consecutive sentence; and (2) the district court in this case did not adequately explain the reasons for the consecutive sentence. Remanded.
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