State of Iowa v. L.V. Knighten

IN THE COURT OF APPEALS OF IOWA
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No. 25-0392
Filed January 7, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
L.V. Knighten,
Defendant–Appellant.
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Appeal from the Iowa District Court for Polk County,
The Honorable Paul D. Scott, Judge.
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AFFIRMED
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Erin M. Carr of Carr Law Firm, P.L.C., Des Moines, attorney for appellant.

Brenna Bird, Attorney General, and Joshua Henry, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Greer, P.J., and Schumacher and Ahlers, JJ.
Opinion by Greer, P.J.

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GREER, Presiding Judge.

L.V. Knighten pled guilty to felon in possession of a firearm. On
appeal, Knighten argues the district court abused its discretion because the
court failed to consider mitigating factors that supported his request to be
placed on probation and receive treatment at a Veterans Affairs (VA)
program.1 Instead, the district court, exercising its discretion, weighed other
negative factors and sentenced him to five years’ incarceration, concurrent
with a pending probation matter. We affirm.

I. Background Facts and Proceedings.

In September 2023, Knighten had a gun in his backpack, although he
was prohibited from possessing the weapon because he is a convicted felon.
He claimed he had the gun for protection from break-ins that had occurred
in his apartment. While wearing the backpack, he offered a woman a ride on
his motorcycle. When she grabbed his backpack to get better leverage, the
gun went off. The woman was shot in the leg, and Knighten transported her
to the hospital. Staff at the hospital notified the police, and Knighten was
arrested. Knighten was charged with: count I felon in possession of a firearm
in violation of Iowa Code section 724.26(1) (2023), and count II possession
of a controlled substance, second offense, in violation of Iowa Code
section 124.401(5).

Knighten and the State entered a plea agreement to dismiss count II
with the agreement that the State would recommend any sentence run

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Knighten challenges the sentence imposed rather than his guilty plea and has
good cause to appeal. See Iowa Code § 814.6(1)(a)(3) (2025); State v. Damme, 944
N.W.2d 98, 104–05 (Iowa 2020). The State acknowledges that Knighten challenges the
sentence, and the sentence was not mandatory under the plea agreement.

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concurrently to some probation violation matters. Knighten pled guilty to
felon in possession of a firearm and the matter was set for sentencing.

At the sentencing hearing in February 2025, Knighten emphasized his
health conditions and the six-week VA mental-health residential
rehabilitation treatment program he could attend if probation was imposed.
The State highlighted his long and storied criminal history. The district court
considered the presentence investigation (PSI) report and addendum, the
statements of the attorneys and Knighten at the sentencing hearing, the VA
program, the events surrounding the offense, Knighten’s characteristics, and
all available sentencing options. The district court noted that this case was
“difficult” considering Knighten was sixty-four years old at the time, but the
court also considered his many violations of the law concluding that he had a
“complete disregard for following the law.” An additional aggravating factor
was that, at the time he committed the felon-in-possession-of-a-firearm
violation, he was on probation for the same offense. Ultimately, the district
court sentenced Knighten “to an indeterminate term of incarceration not to
exceed five years.” He appeals.

II. Standard of Review.

“We review challenges to sentences within the statutory limits for an
abuse of discretion.” State v. Luke, 4 N.W.3d 450, 455 (Iowa 2024) (cleaned
up). “An abuse of discretion will not be found unless we are able to discern
that the decision was exercised on grounds or for reasons that were clearly
untenable or unreasonable.” State v. Formaro, 638 N.W.2d 720, 724 (Iowa
2002).

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III. Analysis.

Knighten argues the district court abused its discretion by failing “to
provide proper weight to several mitigating factors that supported a lighter
sentence than what was imposed.” Specifically, he points to his lack of recent
probation violations, desire to change, acceptance into the VA program, age,
physical and mental health, and acceptance of responsibility. “[A] sentence
within the statutory limits is cloaked with a strong presumption in its favor
. . . .” Id. Knighten “must overcome the presumption in favor of the
sentence by affirmatively demonstrating the court relied on an improper
factor or based its decision on clearly untenable grounds.” State v. Pirie, 18
N.W.3d 238, 249 (Iowa 2025) (cleaned up). The question on appeal is not
whether we would have imposed the sentence, “but rather, whether the
sentence imposed was unreasonable.” State v. Wickes, 910 N.W.2d 554, 572
(Iowa 2018) (cleaned up).

Here, the district court sentenced Knighten to an indeterminate term
not to exceed five years—within the statutory limits under Iowa Code
section 724.26(1). In imposing sentences, the district court considers which
sentence “will provide maximum opportunity for the rehabilitation of the
defendant, and for the protection of the community from further offenses by
the defendant and others.” Iowa Code § 901.5. The court weighs several
factors, “including the nature of the offense, the attending circumstances,
the age, character and propensity of the offender, and the chances of reform.”
Formaro, 638 N.W.2d at 725. Additionally, the court must “consider the
defendant’s prior record of convictions or deferred judgments, employment
status, family circumstances, and any other relevant factors.” Id. The court
is required to explain “its exercise of discretion by stating on the record the
reasons for imposing a particular sentence,” but “it is generally not required

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to give its reasons for rejecting particular sentencing options.” State v. Smith,
17 N.W.3d 355, 360 (Iowa 2025) (cleaned up).

Knighten argues that the court failed to properly weigh the mitigating
factors of his age, mental health, physical health, and acceptance of
responsibility. At the sentencing hearing, the court stated that among other
information it considered the PSI report and statements from Knighten,
which included information about his age, mental health, physical health, and
Knighten’s acceptance of responsibility. See State v. Sando, No. 23-1091,
2024 WL 2043151, at *2 (Iowa Ct. App. May 8, 2024) (affirming a sentence
when the mitigating factors “were placed squarely before the court when it
reached its sentencing decision” and the defendant failed to affirmatively
show the court did not consider them (citing Wickes, 910 N.W.2d at 572)).
The district court explained that it sentenced Knighten primarily based on
his criminal history and the fact that he was on probation for the exact same
offense that he committed here. See Smith, 17 N.W.3d at 359. The court was
not required to acknowledge all of Knighten’s claimed mitigating factors in
its explanation. State v. Boltz, 542 N.W.2d 9, 11 (Iowa Ct. App. 1995) (noting
“the failure to acknowledge a particular sentencing circumstance does not
necessarily mean it was not considered”). And here the district noted in its
sentencing order its consideration of Knighten’s rehabilitation; protection of
the community from further offenses; the nature of the offense; treatment
opportunities available in both the community and correctional system; and
Knighten’s age, criminal history, employment and family circumstances, and
mental-health and substance-use history.

All and all, we find that the sentencing court properly exercised its
discretion and the sentence imposed was reasonable. The PSI report
recommended incarceration. The report showed that Knighten had a high

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probability of future violence and future victimization. Also included in the
report was information about the likelihood of Knighten’s recidivism. And
though Knighten urged the court to grant him probation so he could receive
treatment at the VA program as an alternative to incarceration, he had just
recently failed to complete a VA inpatient program when he left against
medical advice, failed to show for an appointment the following month, and
failed to follow through on getting set up with his VA mental-health case
workers. Thus, the district court exercised appropriate discretion, as its
sentencing “decision was not based on grounds clearly untenable or to an
extent clearly unreasonable.” Wickes, 910 N.W.2d at 572 (cleaned up).

IV. Conclusion.

Upon our review, we affirm Knighten’s sentence.

AFFIRMED.

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