State v. Rutherford
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The Supreme Court affirmed Defendant's judgment of sentence and confirmed what it held in State v. Wilbourn, 974 N.W.2d 58 (Iowa 2022) and State v. Treptow, 960 N.W.2d 98 (Iowa 2021), that if good cause is lacking to bring a criminal appeal, an appellate court has no jurisdiction, and the appeal must be dismissed.
Defendant pleaded guilty to second-degree theft and was sentenced to three consecutive five-year sentences of imprisonment. The court of appeals affirmed the sentence after finding good cause to address Defendant's challenge to his sentence under Iowa Code 814.6(1)(a)(3). The court declined to address Defendant's assertion that there was an inadequate factual basis to support his guilty plea to theft based on a lack of good cause. The Supreme Court affirmed in part and vacated the judgment in part, holding (1) because the court of appeals had jurisdiction over this appeal it should have also addressed Defendant's challenge to the factual basis supporting his guilty plea; and (2) even though this Court had jurisdiction over Defendant's appeal, it lacked the authority to resolve his factual basis challenge.
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