State v. Schuler

APPEL, Justice.

This case centers on the validity of the jury instruction for the crime of willful injury causing serious injury. The defendant asserts that the instruction fails to set forth the elements of willful injury as established by the Code of Iowa. Specifically, he alleges that the instruction impermissi-bly lowered the State’s burden of proof by requiring that it prove only that the victim “sustained” a serious injury instead of demonstrating that the defendant’s actions “caused” a serious injury. For the reasons expressed below, we agree with the defendant, reverse his conviction,…