State of Iowa v. Jordan McKim Crawford, 20-0280

Background

May 30, 2018 ATM cut and June 1, 2018 armed robbery of Pilot Grove Savings Bank in Packwood involved Ethan Spray (trier/robber), Ross Thornton, and Jordan Crawford; Spray testified under a plea deal.
Spray said Crawford operated an acetylene torch on the ATM job, provided the ski mask used in the bank robbery (but allegedly failed to provide gloves), helped burn money bands afterward, and rode in/used a dark truck registered to Crawford.
Phone records show multiple calls between numbers tied to Thornton and Crawford around the bank robbery; Spray and Thornton later traveled to Oregon with Thornton’s son.
After returning, Facebook messages from Crawford advertised multiple pounds/strains of marijuana; law enforcement found $470 and a personal-use amount of marijuana in Crawford’s car and bait money in Thornton’s home.
A jury convicted Crawford of aiding and abetting first-degree robbery and ongoing criminal conduct; on appeal he challenged sufficiency of evidence, alternatively ineffective assistance of counsel, and argued §814.7 is unconstitutional; he also urged adoption of plain-error review.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency — aiding & abetting 1st-degree robbery	Evidence (mask, truck registration, phone calls, burning money, participation) supports that Crawford knowingly aided/approved the robbery.	No preserved specific challenge to elements (e.g., knowledge of gun); trial motion was non‑specific; Spray’s credibility and lack of gloves undermine proof.	Error on specific elements (knowledge of gun/use) not preserved; conviction affirmed. (State concedes lack of evidence of knowledge of a gun if that issue had been preserved.)
Sufficiency — ongoing criminal conduct (continuing-basis & specified acts)	Predicate acts: ATM theft, bank robbery, and Facebook evidence of attempted marijuana distribution constitute an enterprise and continuing criminal conduct.	Evidence of two robberies a few days apart plus solicitations weeks later is insufficient to show a threat of ongoing criminal activity or completed drug distribution.	Under the unobjected-to marshalling instruction, proof of any listed specified act sufficed; though proof of a "continuing basis" was thin, defendant failed to preserve that specific objection; conviction affirmed.
Ineffective assistance of counsel / §814.7 constitutionality	§814.7 properly channels ineffective-assistance claims to postconviction relief and is constitutional; direct-appeal IAC claims are barred.	§814.7 violates due process and separation of powers and denies effective appellate counsel by preventing IAC claims on direct appeal.	Precedent controls: §814.7 is constitutional and IAC claims must be raised in postconviction proceedings; direct-appeal resolution is barred.
Request to adopt plain-error review	Appellate courts should not create a plain-error rule; precedent declines it.	Defendant asks the court to adopt plain error to reach his unpreserved claims.	Court declines and follows Iowa precedent that refuses to adopt plain-error review.

Key Cases Cited

State v. Olofson, 958 N.W.2d 225 (Iowa Ct. App. 2021) (standard for reviewing sufficiency of the evidence).
State v. Truesdell, 679 N.W.2d 611 (Iowa 2004) (motion for acquittal must identify specific grounds to preserve insufficiency claim).
State v. Greene, 592 N.W.2d 24 (Iowa 1999) (specificity required in a motion for judgment of acquittal).
State v. Williams, 695 N.W.2d 23 (Iowa 2005) (non-specific motions do not preserve issues unless the grounds are obvious).
State v. Banes, 910 N.W.2d 634 (Iowa Ct. App. 2018) (failure to object to jury instruction makes it the law of the case for sufficiency review).
State v. Reed, 618 N.W.2d 327 (Iowa 2000) (defines "continuing basis" for ongoing criminal conduct offenses).
State v. Lilly, 908 N.W.2d 293 (Iowa 2019) (IAC from failure to move for acquittal is properly raised in postconviction relief).
State v. Treptow, 960 N.W.2d 98 (Iowa 2021) (due process requires a forum to present IAC claims; §814.7 channels them to PCR).
State v. Macke, 933 N.W.2d 226 (Iowa 2019) (§814.7 bars deciding ineffective-assistance claims on direct appeal).
State v. Tucker, 959 N.W.2d 140 (Iowa 2021) (§814.7 does not violate separation of powers or divest the court of jurisdiction).
State v. Rutledge, 600 N.W.2d 234 (Iowa 1999) (Iowa courts decline to adopt plain-error review).
State v. McCright, 569 N.W.2d 605 (Iowa 1997) (same).
State v. Miles, 344 N.W.2d 231 (Iowa 1984) (same).