State of Iowa v. Loren Patrick Cramblit
CourtCourt of Appeals of Iowa
Date FiledNovember 4, 2026
Docket25-1668
StatusPublished
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Full Opinion
IN THE COURT OF APPEALS OF IOWA
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No. 25-1668
Filed November 4, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Loren Patrick Cramblit,
Defendant–Appellant.
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Appeal from the Iowa District Court for Polk County,
The Honorable Paul D. Scott, Judge.
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AFFIRMED AND REMANDED
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Erin M. Carr of Carr Law Firm, P.L.C., Des Moines, attorney for appellant.
Brenna Bird, Attorney General, and Adam Kenworthy, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Schumacher, P.J., and Langholz and Sandy, JJ.
Opinion by Schumacher, P.J.
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SCHUMACHER, Presiding Judge.
Loren Cramblit appeals following guilty pleas for assault causing bodily
injury in violation of Iowa Code section 708.2(2) (2024) and fourth-degree
criminal mischief in violation of sections 716.1, 716.6(a)(1), and 716.6(b),
asserting the district court abused its discretion when fashioning the
sentence and imposed an illegal sentence. Upon our review, we find no abuse
of discretion in the court’s consideration of relevant sentencing factors but
remand to the district court for the limited purpose of entering a nunc pro
tunc order to correct a mathematical error concerning the length of the
sentence.
I. Background Facts & Proceedings
At an intersection in West Des Moines, Cramblit got out of his vehicle
and punched the back window of the victim’s car, causing the window to
shatter. The victim got out of her vehicle and approached Cramblit. Cramblit
then struck the victim in the face with his hand, causing injury.
The State charged Cramblit with willful injury resulting in bodily
injury and fourth-degree criminal mischief. Cramblit entered into a plea
agreement in which he would plead guilty to assault causing bodily injury and
fourth-degree criminal mischief in exchange for the State recommending
thirty days’ incarceration and a year of probation. At sentencing, Cramblit
argued the court should neither place him on probation nor order
incarceration.
The district court sentenced Cramblit to a suspended sentence of 365
days in jail on each count, to be run consecutively, and placed him on
probation for two years. When fashioning the sentence, the court considered
several factors, including the nature of the offense, Cramblit’s criminal
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history, his age, his need for rehabilitation, the protection of the community,
and the harm to the victim.
Cramblit now appeals, arguing the district court illegally sentenced
him by exceeding the statutory maximum sentence. He also argues the court
abused its discretion in fashioning the sentence.
II. Analysis
We first consider Cramblit’s assertion that the district court abused its
discretion in fashioning the sentence. “[T]he decision of the district court to
impose a particular sentence 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. Formaro,
638 N.W.2d 720, 724 (Iowa 2002). Abuse of discretion in sentencing occurs
when “the decision was exercised on grounds or for reasons that were clearly
untenable or unreasonable.” Id.
“In applying the abuse of discretion standard to sentencing decisions,
it is important to consider the societal goals of sentencing criminal offenders,
which focus on rehabilitation of the offender and the protection of the
community from further offenses.” Id. “It is equally important to consider
the host of factors that weigh in the often arduous task of sentencing a
criminal offender, including the nature of the offense, the attending
circumstances, the age, character and propensity of the offender, and the
chances of reform.” Id. at 725. “Furthermore, before deferring judgment or
suspending sentence, the court must additionally consider the defendant’s
prior record of convictions or deferred judgments, employment status, family
circumstances, and any other relevant factors, as well as which of the
sentencing options would satisfy the societal goals of sentencing.” Id.
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Cramblit argues the district court disregarded mitigating factors,
including that he completed an anger management course, maintained a
business, and did not commit another crime since the offense, which
amounted to an abuse of discretion.
Here, the district court appropriately considered Cramblit’s history
and characteristics, his age, his needs for rehabilitation and correctional
treatment, the nature of the offenses, and the protection of the community.
The court also considered Cramblit’s completion of an anger management
course. That the court did not specifically reference other mitigating factors
does not amount to an abuse of discretion. See State v. Barnes, No. 24-1958,
2025 WL 3171298, at *3 (Iowa Ct. App. Nov. 13, 2025) (noting “the court has
no obligation to address each claimed mitigating factor or the evidence
supporting it”).
We find the district court did not abuse its discretion in fashioning
Cramblit’s sentence.
We next turn to Cramblit’s illegal sentencing challenge. A challenge to
an illegal sentence may be raised at any time. Dorsey v. State, 975 N.W.2d 356,
363 (Iowa 2022). “A challenge alleging that a sentence is illegal is reviewed
for errors at law.” State v. Boehmer, 967 N.W.2d 191, 193 (Iowa Ct. App. 2021).
Cramblit asserts that the district court illegally sentenced him to a
sentence beyond the statutory maximum for two serious misdemeanors,
which is 730 days, or 365 days per count. Iowa Code § 903.1(1)(b). Here, the
court’s oral sentencing pronouncement and the sentencing order stated the
total term of incarceration was not to exceed 760 days. The State concedes
the court made a mathematical error.
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We find the errors in the sentencing pronouncement and order were
clerical in nature. See State v. Kramer, 11 N.W.3d 794, 799 (Iowa Ct.
App. 2024). Errors are considered clerical when they are “not the product of
judicial reasoning and determination.” State v. Hess, 533 N.W.2d 525, 527
(Iowa 1995). “[W]hen the record unambiguously reflects that a clerical error
has occurred, we will direct the district court to enter a nunc pro tunc order
to correct the judgment entry.” Id. Accordingly, we remand to the district
court to enter a nunc pro tunc order to reflect the maximum term of
incarceration on the consecutive counts to be 730 days.
III. Conclusion
We find no abuse of discretion in the court’s consideration of relevant
sentencing factors, but we remand to the district court for the limited purpose
of entering a nunc pro tunc order to reflect the maximum term of
incarceration on the consecutive counts to be 730 days.
AFFIRMED AND REMANDED.
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