State of Iowa v. James Robert Downey, 15-1585

James Downey applied for an annual permit to acquire pistols/revolvers and signed a certification that he would not make any false statement of material fact on the application.
On the application he answered “No” to whether he had ever been convicted of a felony or a crime involving a firearm/explosives punishable by more than one year.
Downey had a prior conviction for OWI, third offense, a class D felony, which he later stipulated.
A Johnson County sheriff’s captain contacted Downey and confirmed he completed the application; the captain also testified Downey acknowledged the felony and that “No” was incorrect.
The State charged Downey under Iowa Code § 724.17 for knowingly making a false statement of material fact on the application.
The district court found Downey guilty; he appealed, challenging identity, whether the question was required, materiality, and knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Identity of applicant	Application and sheriff’s call established Downey completed it	Insufficient proof tying Downey to the application	Court found substantial evidence Downey was the applicant; identity proved
Whether question was part of statutorily required application	Even if not specifically listed, the statute criminalizes false statements on the application	Question not statutorily authorized, so answer not required or material	Court declined to resolve authorization; relied on statutory prohibition of knowingly false material statements on applications
Materiality of the false answer	Felon status is decisive to permit approval; therefore answer was material	Background check would have revealed the felony regardless, so the answer was irrelevant	Court held the question was material because it was decisive to disqualification
Knowledge (mens rea)	Downey knew of his felony, knew it disqualified him, and knowingly answered falsely	Experts testified the question was ambiguous, creating doubt about knowledge	Court credited captain’s testimony over experts and found substantial evidence Downey knowingly made a false statement

State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (standard for reviewing sufficiency of evidence and when fact findings bind appellate court)
Butler v. United States, 317 F.2d 249 (8th Cir. 1963) (identity may be established from surrounding facts and circumstances)
State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (trier of fact not required to accept expert opinion as conclusive)
State v. Hoyman, 863 N.W.2d 1 (Iowa 2015) (interpretation of “knowing” in criminal statutes and limits on breadth of mens rea)