State of Iowa v. Ronald Lee Rand
16-1810
| Iowa Ct. App. | Oct 11, 2017Background
- On Dec. 13, 2015, Ronald Rand shot Michelle Key; bystanders and police found Key mortally wounded and Rand covered in blood; Rand made statements to officers admitting he shot her and saying “I didn’t mean to do it” and “I lost it.”
- Rand told officers he retrieved a shotgun, pointed it to scare Key after learning of her infidelity, and claimed Key grabbed the barrel causing the gun to discharge; he gave inconsistent accounts about whether the gun was loaded and whether his finger was on the trigger.
- Social-media posts shortly before the killing referenced Key’s affairs and mentioned "mental homicide;" Rand had posted photos of himself with the shotgun and had borrowed it after learning of the affairs.
- At trial Rand argued the shooting was accidental while demonstrating the gun; the State argued evidence showed motive, planning, and intentional use of a deadly weapon.
- The jury convicted Rand of first-degree murder; on appeal he challenged sufficiency of the evidence as to premeditation and malice aforethought.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Rand) | Held |
|---|---|---|---|
| Sufficiency of evidence of premeditation | Evidence of motive (affairs), retrieval and display of shotgun, social-media threats, and admissions support premeditation | Shooting was accidental during demonstration; inconsistent statements raise reasonable doubt | Affirmed: substantial evidence of premeditation existed |
| Sufficiency of evidence of malice aforethought | Use of a deadly weapon and hostile relationship permits inference of malice | No specific intent to kill; accidental discharge negates malice | Affirmed: malice could be inferred from deadly weapon and circumstances |
Key Cases Cited
- State v. Buenaventura, 660 N.W.2d 38 (Iowa 2003) (premeditation may be shown by planning, motive, or nature of killing)
- State v. Wilkens, 346 N.W.2d 16 (Iowa 1984) (no minimum time required for premeditation)
- State v. Howse, 875 N.W.2d 684 (Iowa 2016) (standard for reviewing sufficiency of evidence)
- State v. Serrato, 787 N.W.2d 462 (Iowa 2010) (malice aforethought defined; circumstantial evidence supports malice)
- State v. Reeves, 636 N.W.2d 22 (Iowa 2001) (use of a deadly weapon supports inference of malice)