State of Iowa v. Trenton James Greenfield
CourtCourt of Appeals of Iowa
Date FiledSeptember 23, 2026
Docket25-0954
StatusPublished
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Full Opinion
IN THE COURT OF APPEALS OF IOWA
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No. 25-0954
Filed September 23, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Trenton James Greenfield,
Defendant–Appellant.
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Appeal from the Iowa District Court for Polk County,
The Honorable Ashley Stewart, Judge.
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AFFIRMED
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Mark J. Ballard of Springer Law Firm, P.L.L.C., Madrid,
attorney for appellant.
Brenna Bird, Attorney General, and Katherine Wenman, Assistant
Attorney General, attorneys for appellee.
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Considered without oral argument
by Schumacher, P.J., Buller, J., and Vogel, S.J.
Opinion by Buller, J.
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BULLER, Judge.
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
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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.
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