State of Iowa v. Earnest B. Bynum, 937 N.W.2d 319

On March 10, 2016 an anonymous call to Cedar Rapids nonemergency police reported a gray Suburban double‑parked and two men—one with a handgun and one with a rifle—entering a residence owned by Pamela Haskins.
Police responded with drawn weapons, ordered occupants out, searched the house, and found no firearms; Haskins recognized the caller’s phone number as belonging to Earnest Bynum.
Bynum admitted calling the nonemergency line, saying he had seen a Suburban and followed it, and reported it as if it had occurred at Haskins’s home; he said he did not identify the occupants to avoid being a “snitch.”
The State charged Bynum under Iowa Code section 718.6 for making a false report alleging carrying weapons (Iowa Code § 724.4), burglary, or going armed with intent; the jury convicted him of falsely reporting the criminal act of carrying weapons.
At trial Bynum requested a jury instruction that the definition of carrying weapons include statutory exceptions (notably a valid permit to carry); the district court denied the request and instructed only the statutory definition without exceptions.
The Iowa Supreme Court limited review to whether the district court erred in refusing the requested instruction and held Bynum failed to produce substantial evidence of an applicable exception (e.g., a permit), so the court did not err; the conviction and lower-court judgment were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instruction defining the alleged underlying crime (carrying weapons) must include statutory exceptions (e.g., valid carry permit)	Exceptions are affirmative defenses; State need not negate them and court need not instruct on them absent substantial evidence supporting the defense	Omission prevented jurors from assessing whether the reported conduct was actually criminal (permit would make carrying lawful), denying fair trial and effectively directing a verdict	Exceptions are affirmative defenses; defendant produced no substantial evidence (no permit evidence); trial court properly refused instruction; conviction affirmed

State v. Bowdry, 337 N.W.2d 216 (Iowa 1983) (absence of a permit is not an element of carrying weapons)
State v. Erickson, 362 N.W.2d 528 (Iowa 1985) (statutory exceptions to carrying weapons are affirmative defenses)
State v. Leisinger, 364 N.W.2d 200 (Iowa 1985) (State need not negate exceptions unless substantial evidence is produced that an exception applies)
State v. Guerrero Cordero, 861 N.W.2d 253 (Iowa 2015) (requirements for giving a defendant’s requested jury instruction)
State v. Marin, 788 N.W.2d 833 (Iowa 2010) (court must instruct jury on law applicable to all material issues)
In re Winship, 397 U.S. 358 (U.S. 1970) (prosecution must prove elements beyond a reasonable doubt)
State v. Ahitow, 544 N.W.2d 270 (Iowa 1996) (false‑report statute targets affirmative steps to convey false information)
People v. Chavis, 658 N.W.2d 469 (Mich. 2003) (false reporting can apply where a person lies about details of a crime)
Dunne v. Commonwealth, 782 S.E.2d 170 (Va. Ct. App. 2016) (existence of possible defenses to the underlying alleged crime does not excuse a false report)