State of Iowa v. Mark Eugene Robinson, 16-1151

On Jan 1, 2014, Robinson took an idling Ford Taurus from a parking lot and later went into a Kum & Go convenience store.
Robinson asked the lone clerk for two cartons of cigarettes; after failing to swipe his card, he lunged over the counter and grabbed the cartons.
He then put a hand in his pocket in a manner the clerk perceived as indicating a weapon and demanded two more cartons; the clerk complied and Robinson fled.
Surveillance video and clerk testimony were presented at trial; a jury convicted Robinson of second-degree robbery.
On prior appeal the court found sufficient evidence to support the conviction but remanded because the district court used the incorrect legal standard when denying Robinson’s motion for new trial.
On remand the district court denied the new-trial motion; Robinson appealed again claiming the court failed to apply the proper weight-of-the-evidence standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court applied correct weight-of-evidence standard on new-trial motion	State: Court applied the proper standard and reasonably concluded verdict was supported by greater weight of evidence	Robinson: District court did not independently weigh evidence or make credibility determinations; improperly deferred to jury	Affirmed: Court applied proper weight-of-the-evidence analysis and found no error of law

State v. Ellis, 578 N.W.2d 655 (Iowa 1998) (defines motion for new trial as challenging weight of the evidence and requires independent weighing)
State v. Reeves, 670 N.W.2d 199 (Iowa 2003) (appellate review of weight-of-the-evidence claims is limited to review of trial court's exercise of discretion)
State v. Scalise, 660 N.W.2d 58 (Iowa 2003) (trial court must independently weigh evidence and assess witness credibility on new-trial motions)
State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (granting a new trial necessarily invades the province of the jury)
State v. Ary, 877 N.W.2d 686 (Iowa 2016) (new-trial motions on weight of evidence should be granted only in exceptional circumstances)