State of Iowa v. John Dale Metzger, 16-0485

Metzger had a long-standing grievance that crop-dusting planes from Steier Ag flew too low over his property and previously threatened to shoot them down.
On July 31, 2015, Metzger left his home early, drove around gravel roads for about two hours and parked near a Steier airfield while a Cessna crop-duster was operating.
Pilot Derrick Frideres heard a loud metallic pop while flying, later discovered a hole in the right wing flap near the fuel cell, and reported possible gunfire damage.
Investigators recovered a Marlin .22 rifle (and other long guns) from Metzger’s home and found eight cartridge casings on the floor of Metzger’s car; lab testing found lead on the wing damage and .22 test shots were consistent with the hole.
Metzger admitted he sometimes carried rifles and ammunition in his car, had shot skunks from his car, and acknowledged being in the area to watch the planes but denied shooting at the crop-duster.
The State charged Metzger with multiple felonies; the jury convicted him of going armed with intent (Iowa Code § 708.8) and the court sentenced him to an indeterminate five-year term and fine; appeal challenges sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict for going armed with intent	Circumstantial evidence (prior threat, presence in area, rifle in house, casings in car, lab consistency) permits a finding beyond a reasonable doubt that Metzger carried the .22 and shot at the plane	State relied on suspicion and conjecture; no witness saw Metzger move the rifle or shoot; expert couldn't conclusively say a bullet caused the hole	Affirmed — circumstantial evidence viewed in favor of verdict was sufficient
Specific intent to use the rifle against another person	Metzger’s long-standing motive and statements, proximity, and casings support intent to use the weapon against the pilot/plane	No direct proof of intent to use the weapon against Frideres; lack of prior personal connection argued at trial (not renewed on appeal)	Court upheld that jury could infer specific intent from motive and surrounding circumstances
Movement while armed (armed and moved from one place to another)	Metzger admitted driving around with firearms sometimes; he was observed driving/parking near the runway before the incident	No witness saw him carry the rifle from place to place that morning	Jury could infer movement with weapon based on Metzger’s admissions and presence near the plane at the relevant time

State v. Alvarado, 875 N.W.2d 713 (Iowa 2016) (standard for sufficiency review)
State v. Pearson, 514 N.W.2d 452 (Iowa 1994) (reasonable-doubt sufficiency standard guidance)
State v. O’Connell, 275 N.W.2d 197 (Iowa 1979) (circumstantial evidence can be as probative as direct evidence)
State v. Anderson, 517 N.W.2d 208 (Iowa 1994) (jury may disbelieve or credit particular evidence)
State v. Liggins, 557 N.W.2d 263 (Iowa 1996) (giving State reasonable inferences and presumptions in sufficiency review)
State v. Serrato, 787 N.W.2d 462 (Iowa 2010) (motive can support circumstantial evidence when upholding verdict)