State v. Coleman

Appellee pled guilty to a crime listed in Iowa Code 902.12, which requires offenders to serve a mandatory minimum term of their sentence before being eligible for parole or work release. Appellee, who was a juvenile when he committed the offense, was sentenced to an indeterminate term of incarceration. The Iowa Department of Corrections (IDOC) classified Appellee’s sentence as category “B” and calculated his earned time accordingly. Appellee later filed a motion for correction of an illegal sentence based on State v. Lyle. The district court resentenced Appellee to an indeterminate term not to exceed ten years, without the mandatory minimum. The IDOC continued to calculate Appellee’s earned time at the rate provided for in category “B” rather than the faster rate provided for in category “A.” Appellee filed a motion to enlarge the sentencing order, arguing that the IDOC was not giving him full credit for his time served. The district court ruled that Appellee’s entire sentence was subject to the accelerated category “A” accumulation rate. The Supreme Court affirmed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "State v. Coleman" on Justia Law