State of Iowa v. Charles Raymond Albright, 925 N.W.2d 144

Charles Albright and K.H. were long-term partners living together; on October 7, 2016 Albright, under the influence of methamphetamine, assaulted K.H. repeatedly over roughly 13 hours in their Meservey home.
Albright used hands, a cordless drill, a knife, a Taser, and his dog; he threatened to kill her and prevented her from leaving, then forced her into his truck and continued abusing her during trips to a veterinarian and a gas station.
K.H. escaped at a gas station, called 911 from a Dollar General restroom, and exhibited severe injuries (broken nose/dentures, swelling, bruising, bleeding).
The State charged Albright with willful injury causing serious bodily injury (class C felony) and first-degree kidnapping (class A felony); a jury convicted on both counts.
Defense counsel elicited and failed to object to prior-bad-acts and conviction evidence; no limiting instruction was requested. Sentence included prison terms and a restitution order that the district court entered after finding Albright had the reasonable ability to pay.
On appeal Albright challenged sufficiency of kidnapping evidence, the submission of second-degree kidnapping as a lesser offense, counsel’s handling of prior-bad-acts evidence, and the restitution order.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Albright)	Held
Sufficiency of evidence for first-degree kidnapping (confinement/removal and torture)	Evidence of prolonged confinement, movement, and severe abuse supports first-degree kidnapping	Evidence was only incidental to the assault and did not meet kidnapping elements	Conviction affirmed; substantial evidence supported confinement and torture (13-hour confinement increased risk of harm)
Submission of second-degree kidnapping as lesser included offense	No prejudice in submitting lesser offense	Instruction was erroneous and prejudicial	No reversible error; no prejudice where jury convicted of greater offense
Ineffective assistance for failing to object to and eliciting prior bad acts	Admission was permissible trial strategy; not raised on direct appeal	Counsel’s failure/prejudice from introducing other-acts evidence	Not resolved on direct appeal; preserved for postconviction relief because the record doesn’t reveal counsel’s reasons
Restitution order without proper ability-to-pay finding	Court found defendant had ability to pay	Court erred by ordering second-category restitution without amounts before it or full ability-to-pay inquiry	Restitution portion vacated; remanded for restitution ordered consistent with chapter 910 (court must consider reasonable ability to pay when finalizing restitution)

State v. Romer, 832 N.W.2d 169 (Iowa 2013) (framework for viewing evidence in sufficiency review)
State v. Rich, 305 N.W.2d 739 (Iowa 1981) (incidental-confinement rule and three-prong test for kidnapping)
State v. Robinson, 859 N.W.2d 464 (Iowa 2015) (reversing kidnapping conviction where confinement/removal did not exceed that incidental to sexual assault)
State v. Siemer, 454 N.W.2d 857 (Iowa 1990) (kidnapping upheld where confinement substantially increased risk of harm and lessened detection)
State v. Cross, 308 N.W.2d 25 (Iowa 1981) (torture defined as intentional infliction of severe physical/mental pain for kidnapping)
State v. Schertz, 328 N.W.2d 320 (Iowa 1982) (torture found where victim was bound and severely beaten)
State v. Griffin, 564 N.W.2d 370 (Iowa 1997) (upholding kidnapping where prolonged confinement increased risk of detection)
State v. Jackson, 601 N.W.2d 354 (Iowa 1999) (final restitution order requirement and effect on ability-to-pay inquiry)
State v. Haines, 360 N.W.2d 791 (Iowa 1985) (reasonable ability-to-pay/undue hardship standard for restitution)
State v. Williams, 695 N.W.2d 23 (Iowa 2005) (preservation rule and exception where grounds for acquittal motion are obvious)