Iowa Code » Chapter 704 — FORCE — REASONABLE OR DEADLY — DEFENSES
Iowa Code

Iowa Code § 704.10 (2026)

Compulsion

✓ current as of July 2026
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No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another’s threat

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Tue Dec 09 21:56:47 2025 Iowa Code 2026, Chapter 704 (23, 0) §704.10, FORCE — REASONABLE OR DEADLY — DEFENSES 4\n\nor menace of serious injury, provided that the person reasonably believes that such injury is imminent and can be averted only by the person doing such act. [C79, 81, §704.10]

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Notes of Decisions
Cited in 23 cases (4 in the last 5 years), 1978–2022 · leading case: State v. Proctor, 585 N.W.2d 841 (Iowa 1998).
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State v. Proctor, 585 N.W.2d 841 (Iowa 1998). · cites it 12× “The statute states: No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another’s threat or menace of serious injury, provided that the person reasonably…”
State v. Reese, 272 N.W.2d 863 (Iowa 1978). · cites it 4× “The defense of compulsion is provided in § 704.10, 1977 Code Supp., as follows: No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another's threat or menace…”
State v. Walker, 671 N.W.2d 30 (Iowa Ct. App. 2003). · cites it 6× “Iowa Code section 704.10, which was adopted in 1979, reads as follows: No act, other than an act by which one intentionally or recklessly causes physi *35 cal injury to another, is a public offense if the person so acting is compelled to do so by another’s threat or menace of…”
State v. LeCompte, 327 N.W.2d 221 (Iowa 1982). · cites it 4× “” Iowa Code section 704.10 provides the defense of compulsion: No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another’s threat or menace of serious injury,…”
State v. Lake, 476 N.W.2d 55 (Iowa 1991). · cites it 4× “Concededly, the situation presented here will not sustain a defense of compulsion under Iowa Code section 704.10 (1989) or a defense of entrapment.”
Schertz v. State, 380 N.W.2d 404 (Iowa 1985). · cites it 2× “The substance of appellant’s testimony, if she had taken the stand at her criminal trial, would have been that she was coerced through fear into participating in the murder and kidnapping.”
Tully v. State, 730 P.2d 1206 (Okla. Crim. App. 1986). · cites it 2× “§ 35-41-3-8 (West 1978); Iowa Code Ann. § 704.10 (West 1979) (intentional or reckless act causing physical injury); Kan.”
State v. Aldape, 307 N.W.2d 32 (Iowa 1981). “But see § 704.10, The Code 1981: No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another’s threat or menace of serious injury, provided that the person…”
Commonwealth v. Vasquez, 971 N.E.2d 783 (Mass. 2012). “§ 35-41-3-8 (LexisNexis 2009); Iowa Code Ann. § 704.10 (West 2003); Kan.”
Commonwealth v. Robinson, 415 N.E.2d 805 (Mass. 1981). “§ 35-41-3-8 (West 1978); Iowa Code Ann. § 704.10 (West 1979) (intentional or reckless act causing physical injury); Kan.”
United States v. Pete Mitchell, 725 F.2d 832 (2d Cir. 1983). “§ 18-1-708 (1978) (murder in the first degree); Iowa Code Ann. § 704.10 (West 1979) (intentional or reckless act causing physical injury); Ky.”
State v. Hibdon, 505 N.W.2d 502 (Iowa Ct. App. 1993). · cites it 4× “Section 704.10 provides: No act, other than an act by which one intentionally or recklessly causes physical injury to another, is a public offense if the person so acting is compelled to do so by another's threat or menace of serious injury, provided that the person reasonably…”
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