State of Iowa v. Joann Minnie Kamber

Summary

The Iowa Supreme Court held that prior deferred sentences do not constitute deferred judgments or similar relief that would make a defendant ineligible for another deferred judgment under Iowa Code section 907.3(1)(c). The court vacated the Iowa Court of Appeals decision and the defendant’s sentence, remanding for resentencing.

Holdings

1. Section 907.3(1)(c) prohibits a defendant who previously received two or more deferred judgments, including substantially equivalent relief from another jurisdiction, from obtaining another deferred judgment; it does not bar a defendant solely because she previously received two or more deferred sentences.
2. The district court erred by refusing to consider a deferred judgment because Kamber's prior convictions resulted in deferred sentences rather than deferred judgments.

Questions Presented

1. Whether Iowa Code section 907.3(1)(c) bars a defendant who previously received two deferred sentences from receiving a deferred judgment.
2. Whether the district court erred by refusing to consider a deferred judgment as a sentencing option based on Kamber's prior deferred sentences.

Disposition

reversed_and_remanded