State of Iowa v. Brian Todd Thompson

Summary

The court affirmed Thompson’s convictions for two counts of theft by deception. It held that the marshaling instructions were technically inaccurate because they did not expressly connect the deception to the transfers of money, but the error was harmless beyond a reasonable doubt in light of the instructions as a whole, the arguments, and the undisputed evidence. The court also held that Iowa law and the Iowa Constitution permit harmless-error review of instructional errors that omit or misstate an offense element.