State Of Iowa Vs. Stanley Alan Tribble, 2010 Iowa Sup. LEXIS 107

Tribble was convicted of first‑degree murder in Iowa for the death of his wife Tracy after trial where felony-murder was an instructed theory.
Tracy was found May 19, 2006 in the Missouri River near Council Bluffs with blunt‑force head injuries and evidence of asphyxia; toxicology showed 0.25% ethanol.
The district court instructed the jury on two theories of first‑degree murder: willful, deliberate, and premeditated murder, and murder during the commission of a forcible‑felony (willful injury causing serious injury).
The State argued willful injury causing serious injury as the predicate felony; the jury’s verdict showed some members convicted under felony murder and others under the premeditated theory.
The primary legal question on appeal was whether the felony‑murder instruction was proper given the requirement of an independent act separate from the death‑causing act.
The Iowa Court of Appeals affirmed, and this Court granted further review to address the felony‑murder instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the felony‑murder instruction was proper	Tribble argued acts were not independent; actions merged into a single assault.	Tribble contends the head trauma and death were not two separate acts; merger defeats felony murder.	Yes; independent acts supported felony murder and the instruction was proper.

State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (merger and independent‑act limits in Iowa felony murder)
State v. Philo, 697 N.W.2d 481 (Iowa 2005) (time frame for underlying felony and death occurrence)
State v. Galloway, 275 N.W.2d 736 (Iowa 1979) (malice requirement under felony murder; merger context)
State v. Marti, 290 N.W.2d 570 (Iowa 1980) (causation standards in criminal multiple‑cause scenarios)