State of Iowa v. Trel Curtis Peterson

IN THE COURT OF APPEALS OF IOWA
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No. 25-0328
Filed January 7, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Trel Curtis Peterson,
Defendant–Appellant.
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Appeal from the Iowa District Court for Polk County,
The Honorable David M. Porter, 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 Timothy M. Hau, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Tabor, C.J., and Badding and Sandy, JJ.
Opinion by Sandy, J.

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SANDY, Judge.

Trel Peterson appeals the district court’s sentencing decision
following Peterson’s guilty plea to two counts of theft in the second degree.
Peterson argues the district court abused its discretion by declining his
request for probation without consideration of mitigating factors at
sentencing. Finding no abuse of discretion, we affirm the district court’s
sentencing order.

BACKGROUND FACTS AND PROCEEDINGS.
In April 2024, police arrested Peterson for the suspected theft of a
trailer and a Cadillac. The State charged Peterson with two counts of theft in
the first degree, each enhanced due to Peterson’s habitual offender status.
Peterson pleaded guilty to two lesser included counts of theft in the second
degree. The parties agreed to jointly recommend the sentences be ordered
consecutively, allowing parties to argue for prison time or probation at
sentencing.

At the sentencing hearing, Peterson stated that he had committed the
thefts due to his long-term methamphetamine addiction. He stated that he
was pursuing treatment, he was feeling confident he would be able to stay
engaged with treatment, and that he wanted to stay sober. The district court
declined to offer probation due, in part, to Peterson’s prior criminal history.
The district court ordered a thirty-year indeterminate term with at least six
years before Peterson would be eligible for parole. This appeal follows.

STANDARD OF REVIEW.
We review a district court’s sentencing decision for abuse of
discretion. State v. Rasmussen, 7 N.W.3d 357, 363 (Iowa 2024). There is a

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strong presumption that a defendant’s sentence is valid when it is within the
statutory limit. Id.

ANALYSIS.
Peterson contends that the district court abused its discretion by
declining to suspend his term of imprisonment in favor of probation. He
argues the abuse stems from a failure to consider mitigating factors such as
his acceptance of responsibility, desire for rehabilitation, and recent
engagement in treatment. In support of his argument, Peterson contends he
got “himself clean and sober” in the two months prior to his sentencing. He
also asserts that he had a full-time job, was attending Narcotics Anonymous
meetings, had shared custody of his eighteen-year-old son, and did not fail to
report to probation leading up to sentencing.

We are not persuaded by Peterson’s argument. When issuing a
sentencing decision, “[t]he court shall state on the record the basis for the
sentence imposed.” Iowa R. Crim. P. 2.23(2)(g) (2024). This requirement is
intended “to make a defendant aware of the consequences of the defendant’s
actions and to give an appellate court the ability to review the discretion
exercised by the district court.” State v. Phillips, 996 N.W.2d 419, 421 (Iowa
Ct. App. 2023). The district court must determine which legally authorized
sentence best achieves the dual goals of rehabilitation for the defendant and
protection of the community. State v. McCalley, 972 N.W.2d 672, 677
(Iowa 2022). Habitual offenders shall not to be confined for more than fifteen
years. Iowa Code § 902.9(1)(c) (2023). Habitual offenders are not eligible for
parole until they have served the minimum sentence of three years. Id.
§ 902.8. “Our task on appeal is not to second-guess the sentencing court’s
decision.” State v. Damme, 944 N.W.2d 98, 106 (Iowa 2020). Instead, we are

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to determine whether its decision was “unreasonable or based on untenable
grounds.” State v. Formaro, 638 N.W.2d 720, 725 (Iowa 2002).

At the hearing, the district court explained why it declined to offer
probation:

So, Mr. Peterson, what I’m getting at is this. It appears as though the only
time that you walk the straight and narrow is when you’re under
supervision. Okay? Because when you were under supervision and you
were paroled on October 21st, 2022, you did the treatment. All right? You
did what was asked of you. But then when you were a free man for those
two and a half months, you didn’t. . . . You began using methamphetamine,
and then you were engaged in the eluding on January 2nd, 2023. And so
what I’m getting at is the only time it appears as though you walk the
straight and narrow is when someone’s watching you intently.

The district court did specifically address several mitigating factors raised by
Peterson at the sentencing hearing. When addressing Peterson, the district
court stated “I’ve considered your age, your substance abuse history, the nature
of the offenses you committed, the plea agreement, the statutory
requirements, and most importantly for you, Mr. Peterson, I’ve considered
your record of convictions.” (Emphasis added.)

In addition to considering other appropriate factors, the district court
specifically articulated that it did consider Peterson’s substance-use history.
Notably, his ability to stay sober while under supervision, as well as his
inability to stay sober while not under supervision. Peterson’s argument,
essentially, is that he did not get the result he wanted from the district court
at sentencing and feels as though more weight should have been given to his
recent efforts to get sober. The district court did not abuse its discretion by
declining to offer Peterson probation rather than sentencing him to prison.

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CONCLUSION.
We think the district court did adequately consider mitigating factors
and articulated its reasoning for denying probation. The district court cited
Peterson’s criminal history and subsequent prior opportunities to stay on the
“straight and narrow,” yet failing to do so while off supervision in the past.
The district court did not abuse its discretion.

AFFIRMED.

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