State of Iowa v. Delray Daniel Goulette, 16-1515

Delray Goulette drove onto three parcels of private property without permission while hunting; his truck became stuck on one parcel.
The next morning Goulette and a friend attempted retrieval; failing that, a farmer with a front-end loader was enlisted.
During a heavy rain the loader slid into a ravine, properties were damaged, and Goulette did not recover his truck for about three weeks.
The State charged Goulette with three counts of criminal trespass under Iowa law; a jury convicted on all counts.
On appeal, Goulette sought jury instructions on (1) an "act of God" defense based on the rain, and (2) a direction absolving him of liability for damage caused by the farmer’s conduct.
The district court refused both requested instructions; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an "act of God" instruction was required	State: No instruction necessary; evidence did not support it.	Goulette: Rain was sole cause of damage; instruction required.	Court: Not required — rain was anticipated and not sole cause.
Whether jury should be instructed Goulette isn’t responsible for farmer-caused damage	State: Causation links Goulette to harm; instruction would be incorrect.	Goulette: Farmer’s independent acts caused the damage; he should not be liable.	Court: Instruction incorrect as a matter of law — but-for causation ties Goulette to damage.

Lanz v. Pearson, 475 N.W.2d 601 (Iowa 1991) (describes act-of-God defense and its prerequisites)
Oakes v. Peter Pan Bakers, Inc., 138 N.W.2d 93 (Iowa 1965) (act-of-God instruction proper when weather was extraordinary and not reasonably anticipated)
State v. Martinez, 679 N.W.2d 620 (Iowa 2004) (rule requiring requested jury instruction that correctly states law, applies, and is not given elsewhere)
State v. Kellogg, 542 N.W.2d 514 (Iowa 1996) (same jury-instruction standard cited)
Alcala v. Marriott Int’l, Inc., 880 N.W.2d 699 (Iowa 2016) (standard for review of jury instruction claims and errors at law)
State v. Taylor, 596 N.W.2d 55 (Iowa 1999) (discusses preservation and appellate review principles)
State v. Tribble, 790 N.W.2d 121 (Iowa 2010) (explains causation in criminal law and the factual "but for" test)
State v. Marti, 290 N.W.2d 570 (Iowa 1980) (background on causation and criminal responsibility)