State of Iowa v. T.J.W.
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The Supreme Court of Iowa examined a case where a defendant, T.J., was ordered to pay restitution after the court had already dismissed and expunged all charges upon completion of a deferred judgment. T.J. had pleaded guilty to criminal mischief and was placed on unsupervised probation as part of the deferred judgment. After successfully completing the terms of the deferred judgment, the court dismissed and expunged the charge. However, later that day, the court set a hearing for restitution and two months later ordered T.J. to pay over $6,000 in restitution to the victim.
The main question before the court was whether it had the authority to impose a restitution order after the charges had been dismissed and expunged. The court concluded that it did not. The court found that a dismissal and expungement of a criminal charge after successful completion of probation under a deferred judgment should be treated no differently than other situations where a defendant is discharged from probation. The court stated that if a court unconditionally dismisses all pending charges, there's no need for sentencing or any other action by the court before the judgment becomes final. That finality terminates the court’s jurisdiction in the matter.
In this case, the court determined that no statutory or constitutional provision empowered the district court to retain jurisdiction to order restitution after dismissing and expunging criminal charges. Therefore, the court found that it lacked jurisdiction to enter the restitution order after it dismissed and expunged the lone charge in the trial information, and as a result, the order was void. Hence, the writ of certiorari was granted, and the restitution order was vacated.
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