State of Iowa, Plaintiff–Appellee, v. Martin Thicklen, Defendant–Appellant. (2026)

Martin Thicklen appeals his sentence following his conviction of eluding as a habitual offender in violation of Iowa Code section 321.279(2)(a) (2025), asserting the district court abused its discretion by rejecting the parties’ joint recommendation for probation and instead sentencing him to fifteen years of incarceration with a mandatory minimum of three years. Upon our review, we affirm.

I. Background Facts & Proceedings

Law enforcement was surveilling a vehicle registered to Thicklen, who was known to have outstanding warrants and a barred driver's license. Officers eventually saw Thicklen enter the vehicle and drive away through an alleyway. The officers engaged emergency lights and pursued Thicklen, who was driving at least seventy-five miles per hour away from the officers. Thicklen eventually crashed into a parking sign after bottoming out the vehicle. Law enforcement then pursued Thicklen on foot until he gave up the chase. Thicklen was taken into custody and subsequently charged with several offenses, including eluding with speeding, twenty-five miles per hour over the limit. The State provided notice of intent to seek the habitual offender enhancement.

Pursuant to a plea agreement, Thicklen pled guilty to the eluding charge with the remaining charges to be dismissed. The plea agreement also recommended probation conditioned on inpatient substance abuse treatment. The plea agreement recited that the court was not bound by the plea agreement and could sentence Thicklen to the maximum sentence provided by law. At the sentencing hearing, the district court rejected the joint recommendation for probation and instead sentenced Thicklen to fifteen years of incarceration with a mandatory three years on the eluding charge.  ¹ The district court dismissed the remaining charges. Thicklen appeals, challenging his sentence.

II. Analysis

Decisions of a sentencing court “to impose a specific sentence that falls within the statutory limits is cloaked with a strong presumption in its favor, and will only be overturned for an abuse of discretion or the consideration of inappropriate matters.” State v. Damme, 944 N.W.2d 98, 105–06 (Iowa 2020) (cleaned up). When reviewing sentencing decisions, “we must determine [if the district court's] decision was exercised on grounds or for reasons that were clearly untenable or unreasonable.” Id. at 106 (cleaned up). “We afford sentencing judges a significant amount of latitude” when reviewing their sentencing determinations. Id.

Thicklen argues the district court abused its discretion by rejecting the parties’ joint plea recommendation for probation. We disagree. Sentencing courts are not bound by plea agreements between the parties. See State v. Bearse, 748 N.W.2d 211, 216 (Iowa 2008). The goals of a sentencing court are to afford a defendant with a “maximum opportunity to rehabilitate the defendant and to protect the community.” Damme, 944 N.W.2d at 106. When sentencing, the court must weigh several factors including: “the nature of the offense, the attending circumstances, the age, character and propensity of the offender, and the chances of reform,” as well as “the defendant's prior record of convictions ․, employment status, family circumstances, and any other relevant factors.” Id. (cleaned up).

Here, the district court properly weighed relevant factors, including Thicklen's criminal record, mental health, family circumstances, the nature of the eluding offense, substance-use history, and treatment options. Based on these factors, the district court determined that Thicklen would be unlikely to succeed on probation and that incarceration was appropriate. The sentence imposed was not “based on grounds that were clearly untenable or unreasonable.” See State v. Gordon, 998 N.W.2d 859, 862 (Iowa 2023). Accordingly, we find no abuse of discretion and affirm Thicklen's sentence.

AFFIRMED.

FOOTNOTES

1.   This sentence ran concurrently to sentences imposed in three other cases as a result of probation-revocation proceedings.

Opinion by Schumacher, J.