State of Iowa v. Dalton Wayne Cook, 996 N.W.2d 703

On August 2–3, 2018, three men (Bibby, Cook, White) approached a house in Ottumwa armed; Bibby carried an AR-15 rifle and Cook carried a knife.
The group announced a robbery; an altercation outside led to Bibby shooting Colt Stewart in the thigh; the intruders entered the home, threatened occupants, and fled with property.
Police pursued; Bibby and White were shot by officers (White died); Cook was later captured and charged.
Cook was tried as an aider and abettor and convicted of first-degree robbery, first-degree burglary, and willful injury causing serious injury (as to Stewart); other counts were acquitted or merged.
The district court imposed concurrent sentences on robbery and burglary and a consecutive sentence for willful injury; Cook appealed, arguing insufficient evidence for the willful-injury conviction and that the willful-injury conviction should have merged with first-degree robbery.

Issue	State's Argument	Cook's Argument	Held
Sufficiency of evidence for willful injury (aider and abettor)	Evidence showed Cook actively participated: armed presence, knocked Stewart's phone away, entered the home, fled with perpetrators — supporting inference he aided Bibby’s intent or knew of it	Evidence was circumstantial; mere presence and unclear who yelled “Shoot him!” make aiding-and-abetting insufficient	Affirmed. Evidence sufficient when viewed in light most favorable to the State; reasonable jury could find Cook aided/encouraged the willful injury or knew Bibby had that intent
Merger / double jeopardy (whether willful injury must merge with first-degree robbery)	The crimes have different elements: robbery (dangerous-weapon alternative) does not require bodily injury/serious injury; legislature intended multiple punishments	Failure to merge imposed multiple punishments for the same conduct, violating double jeopardy	Affirmed. Legal-elements test shows willful injury requires an additional element (serious bodily injury); merger not required and legislative intent supports multiple punishments

State v. Mathis, 971 N.W.2d 514 (Iowa 2022) (standard for reviewing sufficiency of the evidence)
State v. Brimmer, 983 N.W.2d 247 (Iowa 2022) (definition/instruction for aiding and abetting)
State v. Tangie, 616 N.W.2d 564 (Iowa 2000) (aider liable if acting with requisite intent or knowing principal had it)
State v. Jefferson, 574 N.W.2d 268 (Iowa 1997) (failure to leave or intervene supports aider liability)
State v. Browne, 494 N.W.2d 241 (Iowa 1992) (accompanying a shooter supports inference of encouragement)
State v. Bloom, 983 N.W.2d 44 (Iowa 2022) (standards for merger and double jeopardy review)
State v. Halliburton, 539 N.W.2d 339 (Iowa 1995) (legal-elements test and legislative-intent framework for merger)
State v. Anderson, 565 N.W.2d 340 (Iowa 1997) (if statute provides alternative means, the alternative submitted to the jury controls)