State v. Bloom
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The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of first-degree burglary, first-degree robbery, assault causing serious injury while participating in a public offense and willful injury causing serious injury, holding that remand was required for entry of an order merging Defendant's conviction for willful injury causing serious injury with first-degree robbery.
The court of appeals primarily affirmed the judgment of the district court but agreed with Defendant that his conviction for willful injury causing serious injury merged with his conviction for first-degree robbery. The Supreme Court affirmed, holding (1) the district court's rulings were all correct except as to Defendant's merger claim; and (2) a defendant's prior conviction for vehicular homicide by reckless driving under Iowa Code 707.6A(2) is a "crime of similar gravity" to a forcible felony for purposes of applying the sentencing enhancement set forth in Iowa Code 902.11.
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