State of Iowa v. Justin Patrick Meade

IN THE COURT OF APPEALS OF IOWA

No. 25-0027
Filed October 29, 2025

STATE OF IOWA,
Plaintiff-Appellee,

vs.

JUSTIN PATRICK MEADE,
Defendant-Appellant.
________________________________________________________________

Appeal from the Iowa District Court for Johnson County, Jason A. Burns,

Judge.

A defendant appeals the guilty plea and sentence for his conviction of

harassment in the first degree. AFFIRMED.

Dan Vondra of Vondra Law Office PLC, North Liberty, for appellant.

Brenna Bird, Attorney General, and Anagha Dixit, Assistant Attorney

General, for appellee.

Considered without oral argument by Schumacher, P.J., and Badding and

Langholz, JJ.
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BADDING, Judge.

In a written guilty plea to first-degree harassment, Justin Meade admitted

that he “harass[ed] the victim” and “threaten[ed] to commit a forcible felony.”

According to the minutes of testimony,1 the victim was the owner of a bar who had

once been friends with Meade. And the threat was that Meade would shoot the

victim’s young daughters. The district court accepted Meade’s guilty plea and

sentenced him to 180 days in jail. Meade appeals, claiming that his guilty plea

was not knowing or voluntary because it lacked a factual basis and that the court

abused its discretion by declining to suspend his sentence.

Because Meade’s jail sentence was neither mandatory nor agreed upon, he

has established good cause to proceed with this direct appeal. See Iowa Code

§ 814.6(1)(a)(3) (2023); State v. Hightower, 8 N.W.3d 527, 534 (Iowa 2024). But

even though we have jurisdiction to decide both issues, we lack the authority to

act on Meade’s challenge to the factual basis for his guilty plea. See State v.

Rutherford, 997 N.W.2d 142, 146 (Iowa 2023) (“Even though we have jurisdiction

over Rutherford’s appeal, we must still consider whether we have the authority to

resolve his factual basis challenge.”).

Under Iowa Rule of Criminal Procedure 2.24(3)(a)(2), “[a] defendant’s

failure to challenge the adequacy of a guilty plea proceeding by motion in arrest of

judgment shall preclude the defendant’s right to assert such challenge on appeal.”

This rule does not apply unless the defendant was advised during the plea

proceedings “that challenges to the plea must be made in a motion in arrest of

1 Meade agreed the district court could rely on the minutes to provide a factual

basis for his plea.
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judgment and that the failure to challenge the plea by filing the motion within the

time provided prior to sentencing precludes a right to assert the challenge on

appeal.” Hightower, 8 N.W.3d at 535 (cleaned up).

Meade failed to file a motion in arrest of judgment, and he does not dispute

that he was advised of the need to file the motion and the consequences of failing

to do so. Thus, his challenge to the guilty plea is not preserved for our review.

See State v. Treptow, 960 N.W.2d 98, 109 (Iowa 2021) (stating a “failure to file a

motion in arrest of judgment precludes appellate relief”). Meade contends,

however, that his failure to file the motion resulted from ineffective assistance of

counsel. But that argument is foreclosed by Iowa Code section 814.7, which

deprives us of authority to decide ineffective assistance claims on direct appeal.

See id. Meade’s attempts to avoid the impact of this statute have been rejected

by our supreme court. See, e.g., Rutherford, 997 N.W.2d at 147; Treptow, 960

N.W.2d at 107–08. While Meade urges us to depart from this precedent, we

cannot do so as an intermediate appellate court. See State v. Beck, 854

N.W.2d 56, 64 (Iowa Ct. App. 2014) (“We are not at liberty to overrule controlling

supreme court precedent.”). For these reasons, we lack authority to address

Meade’s challenge to his guilty plea.

This leaves us with Meade’s challenge to his jail sentence. He asserts that

the district court abused its discretion “by failing to adequately consider his needs

for medically managed inpatient treatment for mental health and substance abuse

disorders.” See State v. Martin, 2 N.W.3d 271, 275 (Iowa 2024) (reviewing a

sentence within statutory limits for an abuse of discretion). We disagree.
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Early in the proceedings, Meade participated in an evaluation, which

recommended that Meade receive medically managed intensive inpatient

treatment at an integrated behavioral health facility. Meade agreed with the

recommendation, and he was referred to two integrated behavioral health facilities.

But Meade, who was not in custody while his case was pending, never followed

through with the treatment.

At the sentencing hearing eighteen months later, defense counsel urged the

district court to place Meade on probation so that he could receive mental-health

and substance-use treatment. The court declined to do so, explaining:

[Q]uite a bit of discussion was made about crafting a sentence that
allows you to complete or follow through with the recommendations
for treatment. But you’ve had a year and a half to do so, and you
have neglected to follow through with those recommendations up to
this point.
And although I do agree with [defense counsel] that I don’t like
to warehouse people, as he put it, for substance abuse or mental
health issues, I would also state that anybody that I sentence to a
term of incarceration I’m sentencing not because they have mental
health or substance abuse issues, but because they have violated
the law. And they’ve violated a law that, if I sentence someone to a
term of incarceration, is because I’ve deemed it to be a public safety
concern.
And I’m trying to figure out why a person with as many
resources as you may have has wasted the opportunities as much
as you’ve wasted them. You’ve had a pretty strong recommendation,
that at that time you were in agreement with, of going to one of the
facilities that were deemed to be both leaders in the field of integrated
health is how it is indicated, and you just didn’t do it. And I dare say
that if you had followed through with some of those
recommendations and actually done what was recommended of you,
you may have avoided a number of the issues that you’ve had since
that time.
The charge that’s before the Court at this time is one that I
take very seriously, because if you are, in fact, suffering from mental
health or substance abuse issues, that adds another level of danger
to the situation. You know, if there’s a heat-of-the-moment comment
that’s made, you know, that’s one thing. It’s not excusable, but in
some instances, it’s understandable.
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But if you couple that with untreated mental health concerns
or untreated substance abuse concerns, it elevates what I consider
to be the dangerousness of that situation, because when you make
a threat or you make a statement that you intend to harm another
person, I think the possibility of you following through with that
statement is increased when you have not taken care of those issues
that you should have taken care of.
So I want you to know that I take this matter very seriously.
And I think it’s an aggravating factor that you have not followed
through with the recommendations that were made as part of your
mental health evaluations.

It’s clear from this explanation that the court considered Meade’s need for

treatment. Indeed, Meade seems to concede that point in arguing the court “gave

little consideration” to this issue. Distilled down, he is simply asking us to reweigh

the sentencing factors in Iowa Code section 907.5(1). But that is not our task on

appeal. See State v. Formaro, 638 N.W.2d 720, 725 (Iowa 2002) (noting we are

not “to second guess the decision made by the district court, but to determine if it

was unreasonable or based on untenable grounds”).

“Sentencing decisions that fall within the statutory limits,” as this one does,

“are cloaked with a strong presumption in their favor.” State v. McCalley, 972

N.W.2d 672, 676 (Iowa 2022) (cleaned up). “We afford sentencing judges a

significant amount of latitude because of the discretionary nature of judging and

the source of the respect afforded by the appellate process.” Id. (citation omitted).

“The test for whether a sentencing court abused its discretion is not whether we

might have weighed the various factors differently.” State v. Gordon, 998

N.W.2d 859, 863 (Iowa 2023). The authority to weigh those “competing factors to

reach a sentencing decision is the essence of the discretion given to a sentencing

judge.” State v. Phillips, 996 N.W.2d 419, 422 (Iowa Ct. App. 2023).
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The record shows that the district court acknowledged Meade’s mitigating

circumstances but found that his failure to address his mental-health and

substance-use issues increased the risk to public safety. These were appropriate

and reasonable considerations. See Iowa Code §§ 901.5, 907.5(1). Because

nothing in the record suggests that Meade’s sentence was based on unreasonable

or untenable grounds, we affirm.

AFFIRMED.