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State v. Rankins - Appeal Dismissed, Polk County

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Summary

Iowa Court of Appeals dismissed defendant's appeal challenging consecutive sentences imposed under a plea agreement. The court held defendant failed to establish 'good cause' required to appeal a conviction following a guilty plea to non-class A felony charges. The State had charged Rankins with drug-related offenses including possession with intent to deliver methamphetamine and marijuana, and failure to possess drug tax stamps.

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What changed

The Iowa Court of Appeals dismissed defendant's appeal in State v. Rankins. Following an Alford plea to drug-related charges, defendant received the agreed-upon consecutive sentences totaling up to seventeen years. When defendant later challenged the consecutive nature of his sentence, the court determined he failed to establish the required 'good cause' to appeal a conviction resulting from a guilty plea.

Criminal defendants entering guilty pleas in Iowa face significant limitations on appellate rights. Unless the conviction involves a class A felony, defendants must demonstrate good cause to appeal, which generally requires challenging the sentence rather than the plea itself. However, this exception does not apply when the sentence was mandatory or agreed to in the plea bargain. Defendants receiving plea-agreement sentences should understand their appellate options are substantially restricted.

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Archived snapshot

Apr 15, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

IN THE COURT OF APPEALS OF IOWA

_______________ No. 24-0825 Filed April 15, 2026 _______________

State of Iowa, Plaintiff-Appellee,

Marain Larayondra Rankins,

Defendant-Appellant. _______________ Appeal from the Iowa District Court for Polk County, The Honorable Scott J. Beattie, Judge. _______________

APPEAL DISMISSED

_______________ Matthew B. De Jong of De Jong Law Firm, P.C., Rochester, Minnesota, attorney for appellant.

Brenna Bird, Attorney General, and Olivia D. Brooks, Assistant Attorney

General, attorneys for appellee. _______________ Considered without oral argument By Greer, P.J., and Schumacher and Chicchelly, JJ. Opinion by Schumacher, J.

SCHUMACHER, Judge. Following plea and sentencing, Marain Rankins challenges his

sentence, claiming the district court abused its discretion in imposing consecutive sentences. Because we determine Rankins has failed to establish good cause, we dismiss his appeal.

  1. Background Facts and Proceedings On June 23, 2023, the State charged Rankins with four counts: possession of a controlled substance, methamphetamine, with intent to deliver, a class "B" felony; possession of a controlled substance, marijuana, with intent to deliver, a class "D" felony; and two counts of failure to possess a drug tax stamp, class "D" felonies. Less than a week later, in a separate

criminal case, the State filed a fifth charge: criminal mischief in the third

degree, an aggravated misdemeanor. Pursuant to a global plea agreement, Rankins later entered an Alford plea to possession of controlled substance, marijuana, with intent to deliver; 1 one count of failure to possess a drug tax stamp; and criminal mischief. He also agreed to have his probation revoked in a separate pending matter, with the "original sentence imposed." The parties agreed that the sentences for the three charges would run consecutive to each other for a total term of incarceration not to exceed twelve years, and consecutive to the sentence in the probation revocation matter, for a total term of incarceration not to exceed seventeen years. In exchange for the pleas, the State agreed to dismiss the charge of possession of methamphetamine with intent to deliver and the remaining drug-tax-stamp charge. Rankins requested immediate sentencing

See North Carolina v. Alford, 400 U.S. 25, 37 (1970) (permitting a criminal 1 defendant to enter a guilty plea without admitting guilt).

and waived his right to file a motion in arrest of judgment and his right to

have a presentence investigation report prepared before sentencing. The district court imposed the agreed-upon sentence. Rankins now appeals, arguing the district court abused its discretion in imposing consecutive sentences. The State highlights that our court lacks jurisdiction to address the merits of Rankins's claim because Rankins cannot establish good cause to appeal following his guilty plea, as he received the agreed-upon sentence. See Iowa Code § 814.6(1)(a)(3) (2023) (providing a defendant must establish good cause for an appeal if the conviction results from a guilty plea to a charge other than a class "A" felony). The burden is on Rankins to establish good cause for an appeal. See State v. Damme, 944 N.W.2d 98, 104 (Iowa 2020). Typically, a defendant is able to demonstrate good cause by appealing the sentence rather than the guilty plea. See id. at 105 ("[G]ood cause exists to appeal from a conviction following a guilty plea when the defendant challenges his or her sentence rather than the guilty plea."). But in establishing that good cause exists to appeal the sentence rather than the guilty plea, our supreme court has recognized exceptions when the sentence was either mandatory or agreed to in the plea bargain. State v. Thompson, 951 N.W.2d 1, 2 (Iowa 2020) (citing Damme, 944 N.W.2d at 105). Our court has enforced the exceptions to sentencing challenges, dismissing appeals due to lack of showing of good cause when the sentence imposed is mandatory or the agreed-upon sentence under the plea agreement. See, e.g., State v. Jenkins, No. 21-1828, 2022 WL 16630805, at *3 (Iowa Ct. App. Nov. 2, 2022) (dismissing appeal challenging an agreed-upon sentence as the defendant "has no remedy because she got what she

bargained for and she has not established good cause to appeal"); State v.

McCarroll, No. 20-0641, 2021 WL 4592616, at *2 (Iowa Ct. App. Oct. 6,

  1. (dismissing appeal for lack of good cause due to the sentence imposed being that agreed to by the parties); State v. Major, No. 19-2055, 2021 WL 3662311, at *1-2 (Iowa Ct. App. Aug. 18, 2021) (dismissing appeal when challenged sentence was mandatory); State v. Estabrook, No. 22-1118, 2023 WL 2671954, at *1 (Iowa Ct. App. Mar. 29, 2023) (dismissing appeal when challenged sentence was agreed to by parties). Rankins received the sentences that he agreed to in his plea agreement. He has not established good cause to appeal. Accordingly, we dismiss his appeal.

APPEAL DISMISSED.

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Last updated

Classification

Agency
IA Courts
Filed
April 15th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
No. 24-0825

Who this affects

Applies to
Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Criminal sentencing Appellate review
Geographic scope
United States US

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Employment & Labor

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