Summary
The Iowa Court of Appeals dismissed Bryan Francisco Cordona’s appeal from sentences imposed after he pleaded guilty to two counts of domestic abuse assault. The court held that Cordona failed to show good cause to appeal an agreed sentencing provision and therefore lacked appellate jurisdiction.
Topics
Practice areas
Questions Presented
- Whether Cordona demonstrated good cause to appeal sentences imposed pursuant to an agreed plea bargain after pleading guilty to offenses other than a class A felony.
- Whether the court could reach Cordona's challenge to the agreed personal-search probation condition.
Holdings
- A defendant who pleaded guilty to offenses other than a class A felony must show good cause to appeal, and a challenge directed solely at nondiscretionary or agreed sentencing terms, without an alleged sentencing error extrinsic to the plea, does not establish good cause.
- A defendant may not claim that the court erred by adopting in its entirety the terms of a rule 2.10(3) plea agreement that the defendant requested and accepted.
Key quotations
“And because he pleaded guilty to offenses other than a class “A” felony, Cordona must show good cause to appeal.” (at 1)
“As a result, he cannot now claim the court erred by granting his request to adopt the agreement in its entirety.” (at 2)
“Because Cordona has not shown good cause, we lack jurisdiction and dismiss his appeal.” (at 2)
Factual background
Cordona pleaded guilty to two counts of domestic abuse assault, second offense. Under the plea agreement resolving the aggravated misdemeanor, he agreed to one year in jail with all but fourteen days suspended, two years of probation, and a condition allowing searches of his person, car, or residence during probation. The district court accepted the agreement and imposed the agreed sentence, after which Cordona challenged the personal-search provision on appeal.
Procedural history
In December 2024, Cordona pleaded guilty to two counts of domestic abuse assault, second offense. The Iowa District Court for Plymouth County accepted a rule 2.10(3) plea agreement and imposed the agreed sentence, including a probation condition requiring him to submit to searches. Cordona appealed, but the Iowa Court of Appeals dismissed the appeal for lack of appellate jurisdiction because he did not establish good cause to appeal an agreed sentence.