State of Iowa v. Waylon James Brown

Summary

The Supreme Court of Iowa affirmed Brown’s convictions for first-degree robbery and willful injury causing serious injury, concluding that the evidence supported the robbery conviction and that the offenses did not merge. The court held that first-degree robbery under the dangerous-weapon alternative can be committed without willful injury causing serious injury and that the statutes protect against distinct harms. It also held that the district court did not abuse its discretion by denying a mistrial after COVID-19-related juror absences caused a nine-day trial delay.