Iowa Supreme Court Clarifies Deferred Judgment Eligibility Based on Timing of Prior Convictions

Iowa Supreme Court Clarifies Deferred Judgment Eligibility Based on Timing of Prior Convictions

In State v. Gardner, the Iowa Supreme Court upheld a district court’s ruling that a defendant was ineligible for a deferred judgment because he had been convicted of a felony in a separate case prior to sentencing—even though that felony was committed after the offense in the current case.

Ewaun Gardner was involved in a joint plea agreement covering charges in both Linn and Johnson Counties. He committed the Linn County offense first, but he was sentenced on the Johnson County felony before sentencing in Linn County. At issue was whether the Johnson County conviction—though stemming from a crime committed later—disqualified him from a deferred judgment under Iowa Code section 907.3(1)(a)(1), which bars deferred judgment if the defendant “previously has been convicted of a felony.”

Gardner argued that because the Johnson County offense occurred after the Linn County offense, he should still be eligible. The Iowa Supreme Court rejected this argument, focusing strictly on the timing of the conviction—not the conduct. The Court found the statutory language unambiguous: the presence of a prior felony conviction, regardless of when the underlying offense occurred, renders a defendant ineligible for deferred judgment.

This decision reaffirms the importance of conviction sequence, not offense sequence, in deferred judgment eligibility. It underscores the need for careful coordination in multi-county or multi-case plea agreements and sentencing timing.

As a criminal defense lawyer in Iowa, this ruling serves as a critical reminder that the order in which convictions are entered can determine a client’s eligibility for sentencing alternatives—even if the underlying offense occurred earlier. Strategic case management can make the difference between a deferred judgment and a permanent felony record.