State of Iowa v. Toni Lynn Reese, 15-2200

Toni Reese (grandmother) was convicted by a jury of aggravated misdemeanor harboring of her 13‑year‑old granddaughter, S.P.
S.P. had been living with her father and stepmother (Dawn); after the father died, Dawn obtained guardianship and later withdrew consent for S.P. to stay with her biological mother, Julie.
S.P. went to stay with Julie and Reese in Bridgewater; Dawn requested S.P.'s return, then reported her as a runaway when she was not returned.
During S.P.’s roughly three‑week stay, Reese disconnected calls from Dawn, suggested going "underground" (changing names, cutting hair), gave S.P. medicine, and told S.P. to hide during police visits.
Police executed a search warrant and found S.P. hidden in a clothes dryer at Reese’s home; Reese had been evasive with deputies about S.P.’s whereabouts.
Reese moved for judgment of acquittal arguing insufficient evidence she personally harbored S.P. (claiming Julie, the mother, was the harboring actor); the district court denied the motion and the conviction was appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to convict Reese of harboring a runaway	State: Reese actively aided, sheltered, and concealed S.P., intending to keep her from legal guardian	Reese: Biological mother (Julie) provided the shelter/aid; Reese was not the harboring actor	Affirmed — substantial evidence showed Reese independently aided, sheltered, and concealed S.P.
Whether later withdrawal of guardian consent can make the child a "runaway"	State: Definition covers a child who remains away after guardian withdraws consent	Reese: (acknowledged definition likely expansive) no separate defense offered on this point	Court implicitly accepted the statutory scope — S.P. qualified as a runaway under the facts
Whether mere presence in the house suffices for "harboring"	State: Control of the residence and active steps to evade detection support harboring	Reese: Cited precedent where a mere guest was not guilty of harboring	Court: Distinguished prior guest cases; Reese exercised control over residence and took active steps to harbor S.P.
Whether proof required charging others as co‑culpable	State: Guilt not negated because others also culpable	Reese: Suggested culpability lay mainly with Julie	Court: Multiple actors can be culpable; Reese’s independent actions supported conviction

State v. Howse, 875 N.W.2d 684 (Iowa 2016) (standards for sufficiency-of-the-evidence review)
People v. Ison, 346 N.W.2d 894 (Mich. Ct. App. 1984) (intent to assist juvenile in evading custody supports inference of harboring)