State v. Allen

NEUMAN, Justice.

Defendant, Theodore Allen, appeals his conviction for aiding and abetting the delivery of a controlled substance, cocaine. See Iowa Code § 124.401(l)(c)(3) (1997). His claim for reversal rests on application of the “procuring agent defense,” a theory recognized in State v. Lott, 255 N.W.2d 105 (Iowa 1977), but neither applied in that case nor in subsequent Iowa cases in which it has been raised. We conclude the widely discredited doctrine no longer retains vitality here or elsewhere. We therefore reject Allen’s attempt to rely on it and affirm his conviction.

I. Background…