State of Iowa v. Johnnie Ray Steiger

In this case, we must decide if the defendant was denied procedural protections for determining his status as an habitual offender at trial and whether he needed to preserve error by filing a motion in arrest of judgment. On our review of a decision by the court of appeals, we reverse the judgment and sentences of the district court and remand for further proceedings.

I. Background Facts and Proceedings.

Johnnie Steiger was charged by two trial informations with two separate crimes of indecent exposure. The first trial information also charged Steiger as an habitual offender. This charge…