State of Iowa v. Rodney Dee Brown

Summary

The Iowa Supreme Court affirmed the defendant’s conviction for attempting to entice a minor under Iowa Code section 710.10(4). The court held that the jury instruction did not need to define “illegal act” as an illegal sexual act and concluded that substantial evidence supported the jury’s finding of specific intent. A concurrence agreed with the result but expressed concern that the jury instruction should have identified the specific illegal act or acts alleged by the State.

Holdings

1. No. A defendant may be convicted under section 710.10(4) without intending to commit an illegal sexual act; the statute encompasses illegal acts that are not sexual in nature.
2. Yes. The evidence, viewed in the light most favorable to the State, was sufficient for a rational jury to find beyond a reasonable doubt that Brown intended to commit an illegal act upon the minor.

Questions Presented

1. Whether Iowa Code section 710.10(4) requires a jury instruction specifying that the intended illegal act must be an illegal sexual act.
2. Whether substantial evidence supported the jury's finding that Brown acted with specific intent to commit an illegal act upon the minor.

Disposition

affirmed