Phuoc Nguyen v. State of Iowa

ZAGER, Justice.

In 1999, Phuoc Thanh Nguyen was convicted of first-degree murder. The jury was instructed on both the premeditation and felony-murder alternatives of first-degree murder. The underlying predicate felony was terrorism. 1 The use of an as-saultive predicate felony was supported by a line of cases starting with State v. Bee-man, which found willful injury to be a proper predicate felony for a felony-murder instruction. 315 N.W.2d 770, 776 (Iowa 1982). In 2006, we overturned Beeman in State v. Heemstra, 721 N.W.2d 549, 558 (Iowa 2006). In Heemstra, we held that when a willful…