State of Iowa v. Kent Anthony Tyler III

MANSFIELD, Justice.

This case requires us to consider whether substantial evidence supports the second-degree murder conviction of an individual who struck the first, nonlethal blow in a fatal beating. The defendant’s blow knocked the victim down. Others in the group surrounding the victim then kicked and stomped him to death.

We conclude that substantial evidence supports the jury’s guilty verdict on theories of both principal liability and accomplice liability. However, there is not substantial evidence to support the theory of joint criminal conduct that was also submitted to the jury. Since…