State of Iowa v. Owen F. Benson, 919 N.W.2d 237

On March 6, 2016, Owen Benson struck three children (ages ~8–11) with a broom-handle; only injuries to Z.B. (the 8-year-old) led to charges after bruises were observed and reported.
Forensic medical testimony described Z.B.’s bruises as a high‑impact acceleration/deceleration injury consistent with an object strike and requiring significant velocity.
The State charged Benson with assault causing bodily injury (Iowa Code § 708.1(2)(a), § 708.2(2)) and child endangerment (Iowa Code § 726.6(1)(a), (7)) based on the injury to Z.B.; jury convicted.
Benson argued his punishment was lawful corporal punishment, challenged sufficiency of evidence and the denial of a new trial as contrary to weight of evidence, and objected to jury instructions regarding intent (no marshaling instruction and allegedly inadequate specific‑intent definition).
The Iowa Supreme Court found the evidence was sufficient and the district court did not abuse its discretion in denying a new trial, but held the jury instructions were prejudicially erroneous because they failed to explain which form of intent (specific vs general) applied to each charge; reversed and remanded for new trial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Benson)	Held
Sufficiency of evidence for assault causing bodily injury and child endangerment	Evidence (bruising, forensic opinion, Benson’s admission he used an object to make spanking “sting”) supports specific intent and substantial risk; supports convictions	Conduct was lawful corporal punishment; did not cross line into criminal abuse	Evidence sufficient to support convictions (viewed in light most favorable to State)
Denial of motion for new trial (weight of evidence)	Verdict supported by credible evidence and forensic findings	Verdict contrary to weight of evidence; should grant new trial	No abuse of discretion; not an extraordinary case to overturn verdict
Form of intent required / marshaling instruction	Jury could follow instructions and distinguish intent requirements from closing arguments	Failure to provide an instruction explaining which form of intent applied to each charge misled jury	District court erred by refusing a marshaling instruction; instructions were confusing and prejudicial—requires new trial
Adequacy of specific‑intent definition	Court’s specific‑intent instruction (“specific purpose in mind”) correctly stated law; requested language redundant	Requested language (subjective desire standard) necessary for clarity	Trial court did not err in refusing the requested specific‑intent wording because the given instruction adequately stated the law

State v. Ramirez, 895 N.W.2d 884 (Iowa 2017) (standard for reviewing sufficiency of the evidence)
State v. Wickes, 910 N.W.2d 554 (Iowa 2018) (substantial‑evidence and new‑trial weight‑of‑evidence principles)
State v. Arnold, 543 N.W.2d 600 (Iowa 1996) (parental corporal punishment: line between corrective and abusive)
State v. Fountain, 786 N.W.2d 260 (Iowa 2010) (assault includes a specific‑intent component)
State v. Heard, 636 N.W.2d 227 (Iowa 2001) (assault analyzed as specific‑intent crime)
State v. Bedard, 668 N.W.2d 598 (Iowa 2003) (legislative language does not change substantive elements of assault)
Bacon ex rel. Bacon v. Bacon, 567 N.W.2d 414 (Iowa 1997) (formulation of specific intent as subjective desire for the prohibited result)
State v. Redmon, 244 N.W.2d 792 (Iowa 1976) (specific vs general intent distinction)
State v. Hoyman, 863 N.W.2d 1 (Iowa 2015) (contradictory or confusing jury instructions require new trial)
State v. Coleman, 907 N.W.2d 124 (Iowa 2018) (reversal when jury instructions mislead or materially misstate law)