State v. Keeton
Supreme Court of Iowa
710 N.W.2d 531 (2006)
In March 2004, Keeton (defendant) entered a convenience store, and surveillance video showed him reaching into the clerk's cash drawer and grabbing several $20 bills while checking out. When Keeton tried to leave with the cash, the clerk blocked the exit and tried to grab the money back from his hand; Keeton refused to let go, and his hand touched hers. He briefly backed away but then extended his arm with the cash still in it and moved back toward the door, pulling his hand back as the clerk stepped aside; as he finally left, the angry clerk grabbed his hat. Keeton was convicted of second-degree robbery and appealed, arguing insufficient evidence of the assault element.
Whether, under state law, the mens rea of the assault element of robbery is satisfied if the defendant intended to cause pain or injury, make offensive or insulting physical contact, or make the victim fear immediate painful, injurious, insulting, or offensive physical contact.