State of Iowa v. Jerome Emanuel Bailey Sr.

Summary

The court held that the statutory protection in the extortion statute is an affirmative defense, not an element of extortion, so the defendant bears the initial burden of producing evidence supporting it. Because Bailey's entitlement to the defense depended on disputed factual questions concerning his reasonable belief and good-faith claim to payment, the district court erred by dismissing the charge. The court reversed and remanded for further proceedings.