State of Iowa, Plaintiff–Appellee, v. Mark Anthony Swatta Jr., Defendant–Appellant. (2026)

The sole issue in this appeal, as framed by Mark Swatta Jr., is whether “the court state[d] reasons sufficient to reveal why it selected incarceration for this defendant”? Based on our review of the record, we answer “yes” and affirm.

Swatta pled guilty to one count of possessing methamphetamine—third or subsequent offense, a class “D” felony in violation of Iowa Code section 124.401(5) (2025). The court sentenced him to prison. As its reasoning for doing so, the court orally cited the presentence investigation report, Swatta's “lengthy criminal record,” his poor prospects for treatment or rehabilitation, and the need to protect the public. The written sentencing order cited some of these same factors, as well as Swatta's employment and family circumstances and the nature of the offense.

While Iowa Rule of Criminal Procedure 2.23(2)(f )–(g) requires a statement of reasons for sentencing be placed on the record, our courts have been flexible in how district courts meet that requirement. Even a “terse and succinct” statement is sufficient so long as “the reasons for the exercise of discretion are obvious in light of the statement and the record before the court.” State v. Thacker, 862 N.W.2d 402, 408 (Iowa 2015) (cleaned up). A district court is not required to mention every possible mitigating factor when imposing a sentence. State v. Boltz, 542 N.W.2d 9, 11 (Iowa Ct. App. 1995). Nor is the court required to disclaim every possible lesser sentencing option. State v. Wilbourn, 974 N.W.2d 58, 67 (Iowa 2022).

Against this standard, we find the district court discharged its duty to announce reasons for imposing a prison sentence.

AFFIRMED.

Opinion by Buller, J.