State of Iowa v. Chad Dean Meek, 16-0797

Background

On May 25, 2015, a lone 68-year-old clerk at the Irwin Country Store was robbed shortly before closing by a masked man who displayed a handgun and demanded cash; the clerk surrendered about $590.
A customer called 911, gave the robber's car description and plate; police pursued a Pontiac Grand Prix registered to Chad Meek after spotting it near Defiance; Meek fled at high speed and was stopped about 40 minutes after the robbery.
Deputies recovered an iPhone showing a call to the store near the robbery time, sunglasses, a gun holster, and $590 under the front passenger seat; a loaded Taurus 9mm later was found in a ditch along the chase route and matched a firearm Meek had purchased three weeks earlier.
At trial Meek testified he committed the robbery but claimed he acted under compulsion — alleging unnamed law-enforcement threats to his family — while also making jail-call statements suggesting the seized money was intended to pay a bill.
The jury convicted Meek of first-degree robbery; the district court sentenced him to an indeterminate 25-year term with a 70% mandatory minimum. Meek appealed raising sufficiency/weight of evidence, jury-instruction, evidentiary (photographs, marital privilege), and ineffective-assistance claims.

Issues

Issue	State's Argument	Meek's Argument	Held
Sufficiency — identity	Circumstantial evidence (plate, phone call, items in car) and Meek's admission establish identity	Identity not challenged at trial; raised on appeal	Not considered on appeal; in any event evidence and Meek's own admission support identity
Sufficiency — assault/threat element	Masking, showing a pistol, demands for money satisfy assault/threat element	Clerk didn't visibly panic; Meek didn't point or threaten to shoot	Conduct (masking, weapon display, demand) supports assault/threat; sufficiency affirmed
Sufficiency — compulsion defense	Even assuming compulsion was raised, jury could disbelieve Meek given planning, execution, and inconsistent testimony	Meek claimed trooper threats forced him to commit robbery	Jury entitled to reject compulsion; State met burden by disproving compulsion beyond a reasonable doubt
Weight of evidence / new trial	Evidence credibility and physical corroboration support verdict	Verdict against greater weight; Meek's testimony more credible	No abuse of discretion; verdict not against the weight of evidence
Jury instruction — specific vs general intent	First-degree robbery contains both specific- and general-intent elements (e.g., being armed is general intent)	Inclusion of general-intent instruction conflicted with specific-intent elements	Court properly instructed on both; no reversible error
Evidentiary — admission of patrol photos	Photos corroborated identity and were not unduly cumulative	Photos were duplicative and prejudicial (argued on appeal)	No abuse of discretion; admission harmless given Meek's admission
Marital privilege — jail-call cross-exam	Communication occurred in presence of a trooper (third person) so privilege did not apply	Privilege barred cross-exam about call with wife	Court correctly allowed cross-exam under the "presence of a third person" exception
Ineffective assistance of counsel	Record undeveloped; claims better raised in postconviction relief	Counsel failed to seek mental-health eval, suppress evidence, or investigate compulsion	Preserved for PCR; appellate record inadequate to decide
Cumulative error	Individual claims lack merit	Combined errors deprived Meek of a fair trial	No cumulative error; "zero plus zero equals zero"

Key Cases Cited

State v. Keeton, 710 N.W.2d 531 (Iowa 2006) (standard for reviewing sufficiency of evidence)
State v. Walker, 671 N.W.2d 30 (Iowa Ct. App. 2003) (compulsion defense factors adopted from federal authority)
United States v. Jankowski, 194 F.3d 878 (8th Cir. 1999) (four-factor test for duress/compulsion)
State v. Copenhaver, 844 N.W.2d 442 (Iowa 2014) (robbery/assault elements and intent analysis)
State v. Heard, 636 N.W.2d 227 (Iowa 2001) (assault and robbery precedent)
State v. Parker, 747 N.W.2d 196 (Iowa 2008) (harmless-error analysis where evidence of guilt overwhelming)