State of Iowa v. Wichang Gach Chawech

Summary

The court held that a challenge to a mandatory minimum sentence imposed under Iowa Code section 902.7 is an illegal-sentence challenge and therefore is not barred by error-preservation rules, even when raised for the first time on appeal. On the merits, the court held that the charging instrument need not cite the enhancement statute if it alleges the predicate dangerous-weapon facts and those facts are submitted to the jury and proved beyond a reasonable doubt. The court affirmed the convictions and sentences on counts I, III, and IV, vacated the conviction and sentence on count II because it merged with count III, and remanded for entry of a consistent order.