State of Iowa, Plaintiff–Appellee, v. Trenton James Greenfield, Defendant–Appellant. (2026)

Trenton Greenfield pled guilty to domestic abuse assault with a dangerous weapon and received a deferred judgment in 2023. A term of his probation was to “maintain lawful behavior” and “make all reasonable efforts to show up on time for scheduled meetings” with his probation officer. In January 2025, Greenfield missed a scheduled meeting with his probation officer and a few days later was arrested for a new domestic abuse assault offense.

After a series of continuances to keep the criminal and revocation proceedings moving in parallel, a probation-revocation hearing was held. Greenfield's attorney asked to continue the fifth scheduled hearing date due to scheduling conflicts (or mishaps), and the court denied the request. A different attorney appeared for Greenfield at the revocation hearing, where the arresting officer for the new offense and Greenfield's probation officer testified. The victim did not testify. The court found Greenfield had violated the terms of probation, then revoked his deferred judgment and imposed sentence at a later hearing.

Greenfield appeals, raising three buckets of challenges: due-process and confrontation challenges because the victim did not testify at the hearing; denial of the continuances; and the court finding a probation violation.

We dispose first of the due-process and confrontation challenges. Greenfield did not timely advance these objections below. We thus have nothing to review. E.g., Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002).

Second, we review the denial of a continuance for abuse of discretion. “Because a probation revocation is a civil proceeding and not a stage of criminal prosecution, the rules of criminal procedure do not apply and the proceedings can be informal, even summary.” State v. Duckworth, 597 N.W.2d 799, 800 (Iowa 1999) (cleaned up). “A party challenging a denial of a motion for continuance carries a heavy burden.” Carter v. Carter, 957 N.W.2d 623, 631 (Iowa 2021). Greenfield's appellate brief does not explain why he thinks the court abused its discretion in denying a fourth continuance. Instead he points out that, due to a delay in scheduling the sentencing hearing after the probation-revocation hearing, denying the continuance didn't actually speed up the final disposition. Greenfield cites no authority establishing this reflects an abuse of discretion, we are aware of none, and we reject this claim.

Last, Greenfield contends his commission of the new domestic-abuse offense cannot be the basis for revoking his deferred judgment since the charges resulting from those acts were apparently eventually dismissed. He again cites no authority supporting his position on this issue, and we are aware of none. To the contrary, a finding that a defendant violated terms of probation warranting revocation need only be supported by a preponderance of the evidence—not beyond a reasonable doubt. State v. Kirby, 622 N.W.2d 506, 511 (Iowa 2001). And our case law has long recognized that pending charges may supply the basis for revocation. E.g., State v. Hughes, 200 N.W.2d 559, 562 (Iowa 1972). We discern no basis for relief.

AFFIRMED.

Opinion by Buller, J.