State of Iowa v. Sarah Rae Berg

Summary

The court held that the speedy-indictment rule did not bar the State from charging Berg with unauthorized use of a credit card after the deadline for charging the fourth-degree theft for which she was arrested. The offenses were not the same because they depended on distinct underlying conduct and required different facts for proof. The court affirmed the district court judgment and the court of appeals decision, while allowing the court of appeals analysis on evidentiary sufficiency to stand as the final decision on that issue.