Iowa Code
Iowa Code § 814.28 (2026)
General verdicts
✓ current as of July 2026
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When the prosecution relies on multiple or alternative theories to prove the commission of a public offense, a jury may return a general verdict. If the jury returns a general verdict, an appellate court shall not set aside or reverse such a verdict on the basis of a defective or insufficient theory if one or more of the theories presented and described in the complaint, information, indictment, or jury instruction is sufficient to sustain the verdict on at least one count. 2019 Acts, ch 140, §32
\nNotes of Decisions
Cited in 48
cases (41 in the last 5 years), 2019–2026 · leading case: State of Iowa v. Timothy Alvin Newton, 929 N.W.2d 250 (Iowa 2019).
State of Iowa v. Timothy Alvin Newton, 929 N.W.2d 250 (Iowa 2019). “589, § 32 (West) (codified at Iowa Code § 814.28 (2019)) (barring appellate revision of a verdict “on the basis of a defective or insufficient theory if one or more of the theories presented and described in the complaint .”
State of Iowa v. Carlos Allen Hivento (Iowa Ct. App. 2023). “In relation to his challenge, he also contests the constitutionality of Iowa Code section 814.28 (Supp. 2019) on general verdicts.”
State of Iowa v. Sharon Kay Collins (Iowa Ct. App. 2024). “In relation to this challenge, she argues the savings statute for general verdicts—Iowa Code section 814.28 (2021)—is unconstitutional, and she is therefore entitled to a new trial.”
State of Iowa v. Erica Lyne West Vangen (Iowa 2022). “140, § 32 (codified at Iowa Code § 814.28 (2019)) (prohibiting an appellate court from reversing “a verdict on the basis of a defective or insufficient theory if one or more of the theories presented .”
State of Iowa v. Joshua James Pendleton (Iowa Ct. App. 2023). “In doing so, he contests the constitutionality of Iowa Code section 814.28 (2019) on general verdicts.”
State of Iowa v. Dayquanwne Dashawn Gates (Iowa Ct. App. 2023). “7 Iowa Code section 814.28 provides: When the prosecution relies on multiple or alternative theories to prove the commission of a public offense, a jury may return a general verdict.”
Jamison Albert Fisher v. State of Iowa (Iowa Ct. App. 2024). “2d 741, 754 (Iowa 2016), superseded by statute, Iowa Code § 814.28 (Supp. 2019) (proscribing the appellate court’s reversal of a general verdict as long as one or more theory presented “is sufficient to sustain the verdict”).”
State of Iowa v. Jeremy James Greening (Iowa Ct. App. 2021). “See Iowa Code § 814.28 . We review challenges to the sufficiency of the evidence for correction of errors at law.”
State of Iowa v. Randy Laverne Lee (Iowa Ct. App. 2020). “140, § 32 (codified at Iowa Code § 814.28 (2019)). The new law allows the jury to return a general verdict when the State “relies on multiple or alternative theories to prove the commission of a public offense” so long as the evidence “is sufficient to sustain the verdict on at…”
State of Iowa v. Michael Triplett (Iowa Ct. App. 2021). “Iowa Code § 814.28 (Supp. 2019) (emphasis added).”
State of Iowa v. Jacob Haze Heckethorn (Iowa Ct. App. 2021). “” Compare Iowa Code § 814.28 (“If the jury returns a general verdict, an appellate court shall not set aside or reverse such a verdict on the basis of a defective or insufficient theory if one or more of the theories presented and described in the complaint, information,…”
State of Iowa v. Jasmaine R. Warren (Iowa Ct. App. 2020). “Iowa Code § 814.28 (2019). Judgment of conviction was entered and the sentence was imposed prior to the statute’s effective date.”
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