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The Habeas Citebook Ineffective Counsel

Iowa Supreme Court Announces That ‘Good Cause’ in Newly Amended Appeals Statute Means ‘a Legally Sufficient Reason’

The Supreme Court of Iowa announced that the words “good cause” in the newly amended appeals statute of Iowa Code § 814.6(1)(a)(3) means “a legally sufficient reason.”

Mercedes JoJean Damme pleaded guilty to two counts of theft in the third degree. The State agreed to seek no more than a two-year sentence that would be suspended if Damme was accepted into a program with the Waterloo Women’s Center for Change. The State also agreed to follow any more lenient sentence that may be recommended in her presentence investigation report.

At Damme’s sentencing on July 1, 2019, the trial court rejected the State’s recommended suspended sentence and imposed indeterminate terms of two years of imprisonment on each count to be served concurrently, a $625 fine, a criminal surcharge of 35 percent, court costs, attorney fees, a law enforcement initiative surcharge of $125, and restitution.

Damme appealed her sentence on numerous grounds, but she did not challenge her guilty plea or conviction. The State argued that Damme’s appeal should be dismissed because she failed to establish good cause for the appeal as required by Iowa Code § 814.6 (2019).

The Iowa Supreme Court observed “[t]he Iowa legislature amended Iowa Code section 814.6, effective July 1, 2019, as follows: ‘1. Right of appeal is granted the defendant from: (a) A final judgment of sentence, except in the following cases: ... (3) A conviction where the defendant has pled guilty. This subparagraph does not apply to a guilty plea for a class “A” felony or in a case where the defendant establishes good cause.’” Because the legislature did not define “good cause” within the statute, the Court “look[s] to the common meaning of the term in interpreting the statute.” State v. Tesch, 704 N.W.2d 440 (Iowa 2005). A dictionary can be a reliable source for the common meanings of words. Id. Black’s Law Dictionary defines “good cause” to mean “[a] legally sufficient reason.” Black’s Law Dictionary (11th ed. 2019). The Court adopted that definition.

The burden, then, was on Damme to establish a legally sufficient reason to pursue her appeal because she had been sentenced on the date the amended statute took effect. State v. Macke, 933 N.W.2d 226 (Iowa 2019). And since what constitutes good cause is context-specific, the Court had to determine what would be a “legally sufficient reason to appeal” when a defendant has pleaded guilty. However, as it had often done in past decisions, the Court concluded that the good-cause provision in this case was ambiguous.

Because of the ambiguity, the Court had to determine what the statute meant to accomplish and “seek to advance, rather than defeat, the purpose of the statute.” Rhoades v. State, 880 N.W.2d 431 (Iowa 2016). The statute sought to restrict, and thereby limit, the number of frivolous appeals challenging convictions based on guilty pleas, the Court determined.

But Damme had not challenged her conviction or her guilty plea. She challenged her sentence, which was neither mandatory nor part of her plea bargain. Sentences are invariably imposed after trial courts have accepted guilty pleas. Because this timing provided a legally sufficient reason to appeal notwithstanding the guilty plea, the Court held that “good cause exists to appeal from a conviction following a guilty plea when the defendant challenges his or her sentence rather than the guilty plea.” The Court concluded that based on the facts of this case, “good cause exists to allow Damme’s appeal to proceed.” Turning then to the merits of Damme’s appeal, the Court ruled that “Damme failed to show that the sentencing court relied on improper factors in imposing her sentence,” and thus it found no error.

Related legal case

State v. Damme

 

 

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