State of Iowa v. James L. Mathias, 936 N.W.2d 222

During a high-school football game at the Brady Street Athletic Complex (the Complex) — owned by the Davenport Community School District but not contiguous with the schools’ classroom buildings — James Mathias distributed flyers in the stadium’s south parking lot.
An off-duty Davenport police captain observed Mathias had a firearm; Mathias showed a carry permit and left when told to do so; no immediate arrest was made.
The State charged Mathias under Iowa Code § 724.4B for carrying a firearm "on the grounds of a school." Mathias pleaded not guilty and moved for judgment of acquittal at trial, arguing the Complex was not "grounds of a school."
The district court denied the motion, gave a jury instruction stating that "grounds of a school" may include recreational or cultural facilities, and the jury convicted Mathias.
On appeal Mathias argued (1) insufficient evidence because the Complex is not contiguous to a classroom building and thus not school grounds, and (2) the jury instruction was erroneous because the statute lacks that definition.
The Iowa Supreme Court affirmed, holding school district–owned athletic facilities not contiguous to a classroom building can be "grounds of a school," and the instruction was proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "grounds of a school" under § 724.4B includes district-owned athletic facilities not contiguous to classroom buildings	"Grounds" includes school-owned property used for athletics/events (parking lots, stadiums) and thus covers the Complex	"Grounds" limited to the classroom building and its immediately surrounding, contiguous land; noncontiguous complex not covered	Court: "grounds of a school" can include school district–owned athletic facilities not contiguous to classroom buildings; substantial evidence showed the Complex (and parking lot) qualified as school grounds
Whether the jury instruction defining "grounds of a school" to include recreational/cultural facilities was proper	Instruction accurately construed an undefined statutory term and applied to the facts	Instruction unnecessary or inconsistent with § 280.2 definition of "school"	Court: Instruction properly stated the law after statutory construction and was supported by evidence

State v. Lopez, 907 N.W.2d 112 (Iowa 2018) (statutory interpretation framework and reliance on text/context)
State v. Peterson, 490 N.W.2d 53 (Iowa 1992) ("real property comprising" a school includes contiguous land)
Livingston v. Davis, 50 N.W.2d 592 (Iowa 1951) (broad definition of "school" as a place for instruction)
State v. Finders, 743 N.W.2d 546 (Iowa 2008) (considering the evil a statute seeks to remedy in criminal statutory interpretation)
State v. Becker, 818 N.W.2d 135 (Iowa 2012) (trial judge’s duty to instruct jury on applicable law)