State of Iowa v. Ronald Eugene Cooley

Summary

The Iowa Supreme Court held that the statutory "appear in person" requirement in Iowa Code § 692A.104(2) is an essential element of the offense of failing to register a change of address, and that the trial court’s omission of that element from the marshaling jury instruction was not harmless. Accordingly, the Court reversed Cooley’s conviction, vacated his sentence, and remanded for a new trial with a corrected instruction.