State of Iowa v. Robert Paul Krogmann, 2011 Iowa Sup. LEXIS 80

Krogmann was convicted by jury of attempted murder and willful injury; the convictions were affirmed on appeal.
The State obtained an asset-freeze order blocking Krogmann from using his personal assets (about $3.4 million) to fund his defense.
The district court conditioned asset access on court approval for any sale/transfer of assets; a conservatorship administered by a probate court managed defense-related disbursements.
Krogmann challenged the asset freeze as improper, alleging lack of authority and due process violations.
Separately, the State sought and obtained a restitution lien; Krogmann was ordered to pay victim restitution and prosecution costs.
During trial, a prosecutor questioned Krogmann on his mental state with the remark “Shot anybody today?” which Krogmann later claimed as prosecutorial misconduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Asset-freeze error preservation	Krogmann argues the district court exceeded authority and violated due process.	Krogmann contends the freeze lacked statutory authority and due process protections.	Error preservation failed; asset freeze affirmed, but concerns noted.
Prosecutorial misconduct preservation	Prosecutor’s inflammatory question violated fair-trial rights.	Krogmann failed to request a mistrial or other relief at the time.	Not preserved; no reversible error based on the isolated question.
Impact on fairness of trial	Asset freeze and conservatorship prejudiced defense funding and preparation.	Pretrial controls were insufficiently reviewed due to preservation failures.	Convictions affirmed; no reversible error found on these grounds.

State v. Lyman, 776 N.W.2d 865 (Iowa 2010) (constitutional rights de novo review; totality of circumstances)
State v. Mitchell, 757 N.W.2d 431 (Iowa 2008) (error preservation for constitutional challenges)
State v. Maniccia, 343 N.W.2d 834 (Iowa 1984) (prohibition on inherent injunction in criminal context; authority limits)
State v. Traywick, 468 N.W.2d 452 (Iowa 1991) (timely objection required to preserve issues raised post-trial)
State v. Jackson, 397 N.W.2d 512 (Iowa 1986) (timeliness and preservation of error)
State v. Webb, 244 N.W.2d 332 (Iowa 1976) (prejudice factors in prosecutorial misconduct)
State v. Ruble, 372 N.W.2d 216 (Iowa 1985) (prejudice and requirement of showing impact on fairness)
State v. Boggs, 741 N.W.2d 492 (Iowa 2007) (multifactors for assessing prosecutorial misconduct)
State v. Leckington, 713 N.W.2d 208 (Iowa 2006) (misconduct and prejudice considerations)