Brittany Ione Saxton v. Andrew Lee Kahill, Jr., 21-0199

Parties: Brittany Saxton petitioned for a domestic-abuse protective order against Andrew Kahill after a child-custody exchange involving their six-year-old son.
Incident: Saxton recorded the exchange; she alleged Kahill stepped on her foot, shoved her while she was half‑inside his car, and reached for a concealed firearm; her fiancé, Hargrove, intervened.
Evidence: A short (≈5‑second) phone video captured parts of the encounter but was incomplete and ambiguous; witnesses and an officer largely reported Saxton’s version, but the officer did not interview Kahill at the scene.
Procedural history: District court granted a temporary and then a final protective order under Iowa Code chapter 236; Kahill appealed.
Legal standard: On de novo review, the court must find by a preponderance that a domestic relationship existed and that the defendant assaulted the petitioner under Iowa Code § 708.1.
Holding: The Court of Appeals reversed and remanded, concluding Saxton failed to prove assault under either statutory alternative; the final protective order was to be canceled and the petition dismissed.

Issue	Saxton's Argument	Kahill's Argument	Held
Whether Kahill committed an intentional offensive contact (battery) by stepping on her foot and pushing her	Kahill intentionally stepped on and pinned her and violently shoved her out of the car	He accidentally stepped on her foot while backing away; video shows Saxton escalating and pushing him; actions lack specific intent	No—insufficient proof of specific intent to make offensive contact; step likely accidental and other alleged acts implausible in the short timeframe
Whether Kahill intended to place Saxton in fear of imminent physical contact (assault)	His conduct and alleged reach for a firearm put her in immediate fear	He did not act to create fear; he remained largely silent, called 911, and was subdued by Hargrove; video shows Saxton and Hargrove escalating	No—insufficient evidence of intent to cause fear; video and credibility issues favor Kahill

Christenson v. Christenson, 472 N.W.2d 279 (Iowa 1991) (protective‑order statutes are remedial and protective, not punitive)
Wilker v. Wilker, 630 N.W.2d 590 (Iowa 2001) (appellate court reviews domestic‑abuse protective order records de novo)
State v. Bedard, 668 N.W.2d 598 (Iowa 2003) (assault requires proof of specific intent despite statute’s general‑intent label)
State v. Fountain, 786 N.W.2d 260 (Iowa 2010) (specific intent may be inferred from circumstances)
State v. Redmon, 244 N.W.2d 792 (Iowa 1976) (definition and assessment of specific intent)
State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (intent may be inferred from natural consequences of an act)
Scott v. Harris, 550 U.S. 372 (2007) (courts may allow videotape evidence to ‘speak for itself’)
State v. Yanda, 146 N.W.2d 255 (Iowa 1966) (distinguishing battery and assault concepts)