State of Iowa v. Richard Allen Sharples

Summary

The court held that Sharples’s two out-of-state felony convictions qualified for Iowa’s habitual-offender enhancement because the plain text of Iowa Code section 902.8 requires two prior felony convictions and does not impose the sequencing requirement he urged. The court limited prior same-day-conviction precedent to its facts and affirmed the enhancement. It also held that Sharples failed to show that the sentencing court relied on an improper, uncharged identity-theft allegation in a victim-impact statement.