“Toward Another” Under Iowa’s Assault Statute Does Not Require Pointing a Weapon: State v. Meisheid

Introduction

In State of Iowa v. Matthew James Meisheid, the Iowa Supreme Court addressed whether a defendant “displayed a dangerous weapon toward another” within the meaning of Iowa Code section 708.1(2)(c) when he removed a handgun, held it overhead pointing skyward, and announced to two deputies, “I’ll show you a firework: Boom, boom, boom, boom!” The defendant argued there was insufficient evidence to satisfy the statutory “toward” element because the gun was never pointed in the officers’ direction and was physically moved away from them.

The Court affirmed the conviction, holding that a display can be “toward” a person even if the weapon is not pointed at them or moved in their physical direction, so long as the display is directed at making the person aware of the weapon’s existence. The ruling clarifies the meaning of “toward” in the assault statute and underscores how unobjected-to jury instructions frame sufficiency-of-the-evidence review in Iowa.

Parties:

Appellant: Matthew James Meisheid
Appellee: State of Iowa

Court: Supreme Court of Iowa. Opinion by Justice May; all justices joined. Decision filed October 24, 2025.

Summary of the Opinion

The Court affirmed the district court’s judgment and the court of appeals’ decision, holding that substantial evidence supported the jury’s finding that Meisheid displayed a dangerous weapon “toward” the deputies in a threatening manner under Iowa Code sections 708.1(2)(c) and 708.3A(2). The Court limited its analysis on further review to the “toward” element; it left intact the court of appeals’ resolution of the remaining issues raised—namely, whether the display was “in a threatening manner” and whether the district court abused its discretion in refusing to reduce the mandatory minimum sentence under section 901.10(1).

Key to the Court’s analysis was the unobjected-to jury instruction defining “displayed a dangerous weapon in a threatening manner” as “to show or make apparent to another person that a dangerous weapon existed so as to intimidate the other person.” The Court concluded that, under this instruction and the evidence—including body-worn camera recordings—a reasonable jury could find that the defendant’s act of producing the gun and declaring “I’ll show you a firework” constituted a display directed “toward” the deputies, even though the gun was not pointed at them.

Detailed Analysis

Precedents and Authorities Cited

State v. Miller, 4 N.W.3d 29 (Iowa 2024): Reiterates that upon granting further review, the Iowa Supreme Court has discretion to address any properly preserved issue. The Court exercised that discretion here to decide only the “toward” element; the court of appeals’ disposition of other issues stands as the final decision.
State v. Canady, 4 N.W.3d 661 (Iowa 2024): Confirms that sufficiency-of-the-evidence claims are reviewed for correction of errors at law, anchoring the Court’s deferential posture.
State v. Jones, 967 N.W.2d 336 (Iowa 2021): Emphasizes that sufficiency review is “highly deferential” to the jury verdict.
State v. Lilly, 930 N.W.2d 293 (Iowa 2019) and State v. Harris, 891 N.W.2d 182 (Iowa 2017): Require the Court to view the evidence in the light most favorable to the State and to consider every reasonable inference that supports the verdict.
State v. Brown, 5 N.W.3d 611 (Iowa 2024): Reaffirms that evidence is not insubstantial merely because different conclusions are possible; the question is whether the evidence supports the verdict actually returned.
Iowa Criminal Jury Instruction 800.5 (2025): The model instruction, mirrored in the trial court’s charge, defines “displayed a dangerous weapon in a threatening manner” as showing or making apparent the weapon’s existence so as to intimidate. Although jury instructions are not statutes, the unobjected-to instruction set the operative framework for sufficiency review in this case.

Legal Reasoning

The Court’s reasoning proceeds in three interlocking steps: the standard of review, the operative definition supplied by the jury instructions, and the contextual reading of “toward.”

Standard of Review. The Court stressed the deferential nature of sufficiency review: the evidence is viewed in the State’s favor, reasonable inferences are drawn to support the verdict, and the verdict stands if supported by substantial evidence. This means appellate courts do not reweigh evidence or second-guess credibility determinations, especially where bodycam video and testimony corroborate the State’s proof.
Unobjected-to Jury Instruction as the Lens. Because the defense did not object to the instruction defining “displayed a dangerous weapon in a threatening manner,” the Court evaluated sufficiency under that definition. The instruction allowed a finding of “display” if the defendant “show[ed] or ma[d]e apparent” to another person that a dangerous weapon existed, so as to intimidate. Thus, the “display” element did not turn on muzzle direction or physical proximity but on whether the defendant made the weapon’s existence apparent to the victim to intimidate.
Contextual Interpretation of “Toward.” The defense urged a narrow reading: that “toward” means “in the direction of,” requiring the gun to be physically oriented or moved toward the deputies. The Court rejected this as reading the word “in isolation.” In context, a person can display an object “toward” someone by directing the act of showing at them—causing them to perceive the object—even if the object is not moved closer or pointed at them. The Court’s badge analogy is instructive: an officer displays a badge “toward” a person by holding it where the person can see it, regardless of its spatial orientation. Here, the defendant faced the deputies, removed the handgun, raised it so they could see it, and explicitly linked the demonstration to their fireworks inquiry: “I’ll show you a firework.” A reasonable jury could find that this act was directed at the deputies, satisfying “toward.”

Applying that framework to the facts, the bodycam footage and testimony showed the defendant:

Confronting and verbally accosting the deputies about their presence;
Removing a handgun from his waistband and holding it overhead so the deputies could see it;
Accompanying the display with a declarative statement emphasizing its connection to the deputies’ investigation (“I’ll show you a firework: Boom, boom, boom, boom!”).

Even accepting the defense’s observation that the gun was moved only laterally, to the rear, and skyward—and the muzzle never pointed at the deputies—the Court concluded a rational jury could determine that the display was made “toward” the deputies because it was directed at their awareness and intimidation. That suffices under the instruction and the statute read in context.

The Court also noted that the jury rejected the defense’s factual claim that the object displayed was a meat thermometer, not a gun—a quintessential credibility determination that appellate courts do not disturb under the substantial-evidence standard.

Impact and Implications

1) Clarification of “Toward” in Section 708.1(2)(c)

The decision provides a clear, practical construction of “toward another” in Iowa’s assault statute:

“Toward” focuses on the direction of the display (the communicative act) rather than the orientation of the weapon’s muzzle or the movement of the weapon through space.
A display is “toward another” when the defendant directs the act of showing to the other person to make them aware of the weapon’s existence (and, under the instruction, to intimidate), even if the weapon is not pointed at or moved toward the person.

This clarification will affect charging, jury instructions, and trial proofs in cases involving brandishing or weapon displays—especially where defendants seek to avoid liability by pointing skyward or away while making sure the victim sees the weapon.

2) Reinforcement of the Role of Jury Instructions in Sufficiency Review

The Court’s reliance on the unobjected-to instruction underscores a critical procedural point: in Iowa, unobjected jury instructions typically supply the governing law for sufficiency review. Practically:

Defendants who want to press narrower statutory interpretations must preserve those arguments by objecting to instructions at trial; otherwise, the instruction’s definition will govern on appeal.
Prosecutors and trial courts can look to the Iowa Criminal Jury Instructions for a viable template. The Court’s opinion notes that the trial instruction matched model instruction 800.5, lending support to its continued use.

3) Officer-Assault Prosecutions and Beyond

For prosecutions under section 708.1(2)(c) with the peace-officer enhancement in section 708.3A(2), the State need not prove that a weapon was aimed at or moved toward the officer. The State can satisfy the “toward” element by showing that the display was directed at the officer’s awareness in a manner intended to intimidate. Expect this reasoning to be cited in:

Officer-assault cases involving upward or lateral brandishing;
Domestic or public confrontations where the defendant “shows” a weapon while addressing the victim;
Cases involving non-firearm dangerous weapons (e.g., knives), where the defendant displays the weapon without pointing it at the victim.

4) Open Questions and Boundaries

“Threatening manner”: The Supreme Court did not decide whether the evidence sufficed on this element; the court of appeals’ decision stands, but no new statewide rule was announced by the Supreme Court on that prong.
Minimal displays: Future cases may test the line between an awareness-directed display and mere possession incidentally visible to another. The opinion’s emphasis on the directed, communicative act (including the defendant’s words) suggests that context will remain pivotal.
Sentencing discretion under section 901.10(1): The Supreme Court did not reach this issue; the court of appeals’ decision controls in this case, leaving for another day any broader statewide guidance on when and how district courts should exercise that discretion.

Complex Concepts Simplified

Sufficiency of the evidence: On appeal, the question is not whether the appellate court would have found the defendant guilty. It is whether a rational jury could have found guilt beyond a reasonable doubt when viewing the evidence in the State’s favor and drawing reasonable inferences to support the verdict.
“Substantial evidence”: Evidence that would convince a rational factfinder that the defendant is guilty beyond a reasonable doubt. It can be circumstantial and need not exclude every hypothesis of innocence.
Unobjected-to jury instructions: If a party does not object to a jury instruction, appellate courts typically assess sufficiency of the evidence under the instruction as given, even if the party later argues for a different statutory reading.
“Display[ing] in a threatening manner any dangerous weapon toward another” (Iowa Code § 708.1(2)(c)): As charged here and instructed at trial, this means showing or making apparent to another person that a dangerous weapon exists in a way that intimidates, and doing so “toward” that person—i.e., directing the act of showing at them so they become aware of the weapon.
Peace-officer enhancement (Iowa Code § 708.3A(2)): Elevates the assault to a felony when the assaulted person is a peace officer and the defendant uses or displays a dangerous weapon in connection with the assault.
Mandatory minimum (Iowa Code § 902.7) and possible reduction (Iowa Code § 901.10(1)): Section 902.7 imposes a mandatory minimum term of incarceration in certain offenses involving dangerous weapons. Section 901.10(1) can permit a court to reduce a mandatory minimum in defined circumstances. The Supreme Court did not decide the reduction issue here.

Conclusion

State v. Meisheid establishes a pragmatic and context-sensitive interpretation of “toward another” in Iowa’s assault statute. A weapon is displayed “toward” a person when the defendant directs the act of showing to that person so they perceive the weapon—even without pointing it at them or moving it physically in their direction. The Court’s analysis, rooted in deference to jury verdicts and guided by unobjected-to jury instructions, will meaningfully influence how prosecutors charge, how courts instruct, and how juries evaluate weapon-display assaults, especially in encounters with peace officers.

For practitioners, the case underscores two imperatives: preserve statutory-interpretation arguments through timely instruction objections, and marshal contextual evidence—words, gestures, bodycam footage—that shows the display was directed at the alleged victim. For the public and law enforcement, the ruling clarifies that brandishing a weapon to ensure an officer sees it, even if pointed skyward, can constitute an assault “toward” the officer under Iowa law.