State v. Tippett

Summary

The Supreme Court of Iowa reversed James Clay Tippett's conviction for willful failure to register as a sex offender. The court held that Iowa Code section 692A.7(1) requires proof that the defendant knowingly and intentionally violated a known legal duty to register. Because the State presented insufficient evidence that Tippett knew of an Iowa registration obligation, the court remanded for entry of a judgment of acquittal.

Holdings

1. Proof of willful failure to register requires the State to prove a voluntary and intentional violation of a known legal duty, including that the accused knew registration was required by law.
2. The State presented insufficient evidence to establish that Tippett knew of a legal duty to register in Iowa; the conviction therefore could not stand.

Questions Presented

1. Whether conviction for willful failure to register as a sex offender under Iowa Code section 692A.7(1) requires proof that the defendant knew of the legal duty to register.
2. Whether substantial evidence established that Tippett knew he was legally required to register as a sex offender in Iowa.

Disposition

reversed