State v. Freeman

Supreme Court of Iowa

450 N.W.2d 826 (1990)

Relevant factsFree

Robert Freeman (defendant) sold two grams of a substance he represented as cocaine to Keith Hatcher, who was working with law enforcement, for $200. The substance was actually acetaminophen, not a controlled substance. Freeman believed he was delivering real cocaine. He was convicted of delivering a simulated controlled substance under Iowa Code § 204.401(2) and appealed, arguing he could not be guilty of that crime because he thought he was delivering actual cocaine.

IssueFree

Whether, for criminal offenses with a scienter requirement, mistake of fact is a valid defense only if the mistake negates the necessary mental state for the offense.

Holding & reasoning

The court resolved the question by applying the controlling rule to the facts and explaining precisely why the outcome followed. Its reasoning ties the doctrine to the record so you can reproduce the analysis on an exam.

Procedural history, concurrence & dissent

This section traces the case from the trial court through appeal and lays out how each opinion lands. Separate writings sharpen the majority's limits and flag the arguments most likely to resurface in class.

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