2020] ANALYZING THE VOID-FOR-VAGUENESS DOCTRINE 2361
Iowa Code section 704.13, that granted individuals immunity from criminal
or civil liability when they used reasonable and justifiable force to protect
“oneself, another person, or property.”10 This legislation became effective on
July 1, 2017.11
In State v. Wilson, the Iowa courts interpreted section 704.13 for one of
the first times.12 On August 27, 2017, an altercation between two gangs in
Iowa City’s pedestrian mall culminated in Lamar Wilson shooting three
individuals, with one victim dying and two suffering injuries.13 Iowa charged
Wilson with murder, attempted murder, intimidation with a deadly weapon,
and criminal gang participation.14 Prior to trial, Wilson filed a motion to
dismiss, arguing that he was entitled to a pretrial determination of immunity
under section 704.13.15 However, the district court deferred its decision on
the motion until after trial.16 At trial, a jury found Wilson guilty of voluntary
manslaughter, assault with intent to cause serious injury, and intimidation
with a dangerous weapon.17 Following trial, the district court reviewed
summaries of evidence and depositions submitted by the parties and held that
Wilson was not entitled to immunity under section 704.13.18
The district court denied Wilson immunity under Iowa Code section
704.13 on two bases. First, the district court found that Wilson’s actions did
not fall within the scope of section 704.13 because, based on the evidence, he
Ground and Self-Defense in Florida’s Legal System, 20 BARRY L. REV. 89, 98 (2014) (noting that stand-
your-ground laws are “used as a defense in criminal proceedings”); see also Defense, BLACK’S LAW
DICTIONARY (11th ed. 2019) (defining “defense” generally to mean “[a] defendant’s stated
reason why the plaintiff or prosecutor has no valid case”).
10. IOWA CODE § 704.13 (2018) (“A person who is justified in using reasonable force against
an aggressor in defense of oneself, another person, or property pursuant to section 704.4 is
immune from criminal or civil liability for all damages incurred by the aggressor pursuant to the
application of reasonable force.”).
11. Appellant’s Brief & Argument & Request for Oral Argument at 35, State v. Wilson,
No. 18-0564, slip op. (Iowa Apr. 10, 2020) [hereinafter Appellant’s Brief], available at https://
www.iowacourts.gov/courtcases/7655 /briefs/1898/emb edBrief [https://perma.cc/7QAU-
12. When the Iowa district court decided Wilson, only one defendant, Kevin Staley, had been
granted immunity under Iowa Code section 704.13. Will Greenberg, Johnson County Judge Seeks
Clarity on ‘Stand Your Ground’ Law After Ped Mall Shooting, IOWA CITY PRESS-CITIZEN (Apr. 2, 2018,
1:01 PM), https://www.press-citizen.com/story/news/2018/04/02/iowa-stand-your-ground-
13. Wilson, slip op. at 2 (Iowa Apr. 10, 2020); Stephen Gruber-Miller & Andy Davis, Trial of
Iowa City Ped Mall Shooting Suspect Lamar Wilson Begins This Week, DES MOINES REG., https://
mall-shooting-suspect-lamar-wilson-begins-week/1040270001 [https://perma.cc/TC28-CUP3] (last
updated Jan. 22, 2018, 6:30 AM).
14. Wilson, slip op. at 5 (Iowa Apr. 10, 2020).
15. Id.; Appellant’s Brief, supra note 11, at 18–19.
16. Wilson, slip op. at 6 (Iowa Apr. 10, 2020); Appellant’s Brief, supra note 11, at 19.
17. Wilson, slip op. at 7 (Iowa Apr. 10, 2020).
18. Id.; State v. Wilson, No. FECR116476, slip op. at 6–8 (Iowa Dist. Ct. Mar. 27, 2018).