Supreme Court of Iowa, 2016

The court held that an Iowa sentencing court lacks statutory authority to forfeit a pretrial appearance bond as part of a criminal sentence. Because the forfeiture was included in the sentencing order, the defendant could challenge it directly on appeal without a separate bail proceeding or prior objection.

The court vacated the court of appeals decision, reversed the district court judgment, and remanded for a new trial because the district court improperly submitted negligent training as a specification of negligence and gave a prejudicial instruction concerning private safety standards.

The court held that a statutory presumption favoring consecutive sentences does not eliminate the sentencing court’s duty to explain why it chose a consecutive term. Because the district court’s generalized reasons did not permit meaningful review of that separate discretionary choice, the court vacated the appellate…