State of Iowa v. Travis Howard Richard Beck, 2014 Iowa App. LEXIS 1268

Beck was charged in multiple Iowa cases with assault-related offenses arising from separate incidents in 2011–2012.
Beck sought a mental health evaluation in June 2012; both expert reports supported diminished responsibility.
State filed to adjudicate law points asking whether diminished responsibility is a defense to assault; district court answered yes.
Section 708.1 defines assault with first two alternatives requiring proof of specific intent according to pre-amendment and Heard lineage.
2002 amendment added language stating assault is a general intent crime, but courts later held the amendment did not change the substantive elements for the first two alternatives.
The supreme court ultimately held diminished responsibility is available when the charged offense requires proof of specific intent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether diminished responsibility is a defense to assault.	Beck argues not available due to 2002 amendment and general-intent labeling.	Beck contends specific-intent element remains for first two assault modes; diminished responsibility applies.	Yes; diminished responsibility is available for assault under first two modes.
Does the 2002 amendment to assault affect availability of diminished responsibility	Amendment negates specific-intent defense by labeling assault general intent.	Amendment should preclude diminished responsibility in assault	No; amendment did not strip diminished-responsibility where specific intent remains an element.
What is the controlling interpretation of assault post-amendment with regard to specific vs general intent	Text and history show continued specific-intent requirement for first two modes.	Text suggests general-intent crime; legislators intended to bar diminished-capacity defenses.	First two modes retain specific-intent elements; diminished responsibility remains admissible.
May the 2002 amendment be read to nullify prior case law permitting defenses to specific-intent crimes	Bedard/Keeton/Wyatt/Fountain conflict with amendments; amendment nullifies them.	Amendment’s language and history do not overrule controlling precedents.	No; amendment does not overrule controlling precedents allowing diminished responsibility when specific intent is required.

State v. McVey, 376 N.W.2d 585 (Iowa 1985) (diminished responsibility available where specific intent is element of crime)
State v. Anfinson, 758 N.W.2d 496 (Iowa 2008) (diminished responsibility as a defense to crimes requiring specific intent)
State v. Heard, 636 N.W.2d 227 (Iowa 2001) (assault defined with specific-intent element prior to 2002 amendment)
State v. Bedard, 668 N.W.2d 598 (Iowa 2003) (2002 amendment did not alter elements of assault for first two alternatives)
State v. Keeton, 710 N.W.2d 531 (Iowa 2006) (reaffirmed assault element inquiry post-amendment)
State v. Wyatt, 744 N.W.2d 89 (Iowa 2008) (post-Heard context; careful with label—specific intent remains required for assault elements)
State v. Fountain, 786 N.W.2d 260 (Iowa 2010) (post-conviction context; stated interpretation of ante amendment but not definitive on defenses)