State of Iowa v. Cornelius Tyrone Brown, 16-1118

Background

On June 20, 2015, N.H. awoke to Cornelius T. Brown at her apartment; Brown was an acquaintance and uninvited guest.
Brown assaulted N.H.: punched her repeatedly, pulled her hair, choked her on two occasions, forcibly performed oral sexual contact, stole and returned her phone, and restrained her in the apartment. N.H. feared she would die and sustained bruises, black eyes, scratches, lost hair, and a locked jaw for days.
Police found Brown hiding in a closet; he admitted punching N.H. and that she feared for her life.
Brown was charged with sexual abuse in the second degree (Iowa Code § 709.3(1)) and false imprisonment (§ 710.7), waived a jury, and was convicted after a bench trial.
The district court sentenced Brown to 25 years on the sexual-abuse count and 1 year on the false-imprisonment count and ordered various financial obligations; Brown appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for sexual abuse in the second degree (force creating substantial risk of death or serious injury)	State: evidence of punches, choking, and other violence created a substantial risk of death or serious injury	Brown: State failed to show force created substantial risk of death or serious injury; at most third-degree sexual abuse	Affirmed: evidence (closed-fist punches, two chokes, airway compromise, injuries) sufficient to support conviction for second-degree sexual abuse
Trial court's finding of reasonable ability to pay financial obligations	State: appeal premature because plan of restitution not finalized; obligation to assess ability to pay triggers only after plan is set	Brown: record shows inability to pay and court made no inquiry into ability to pay; requests reversal/remand for factual determination	Appeal is premature: no completed restitution plan when appeal filed, so court did not err at this stage
Ineffective assistance of counsel	State: (not argued)	Brown: requested relief if issues deemed waived and alleged no explanation for counsel’s actions	Court declined to address on direct appeal because defendant made no developed argument; claims preserved for postconviction relief
Standard of review for sufficiency claim	State: (relies on established standards)	Brown: (same)	Court applied established sufficiency standard (view evidence in light most favorable to State; substantial evidence required) and cited Jackson v. Virginia as governing standard

Key Cases Cited

State v. Keopasaeuth, 645 N.W.2d 637 (Iowa 2002) (standard for reviewing sufficiency of evidence)
State v. Sanford, 804 N.W.2d 611 (Iowa 2012) (definition of substantial evidence review)
Jackson v. Virginia, 443 U.S. 307 (1979) (benchmarks for sufficiency of the evidence review)
State v. Howard, 284 N.W.2d 201 (Iowa 1979) (use of bruises and lacerations to show force creating substantial risk of serious injury)
State v. Carter, 602 N.W.2d 818 (Iowa 1999) (compromised airway can create substantial risk of death)
State v. Anderson, 308 N.W.2d 42 (Iowa 1981) (serious injury and substantial risk of death analysis)
State v. Robinson, 859 N.W.2d 464 (Iowa 2015) (scope of appellate review on sufficiency challenges)
State v. Dalton, 674 N.W.2d 111 (Iowa 2004) (consideration of all evidence in record on sufficiency review)
State v. Jackson, 601 N.W.2d 354 (Iowa 1999) (requirement of a completed restitution plan before appellate review of ability-to-pay issues)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (standard of review for ineffective-assistance claims)