State v. McKee
Iowa Supreme Court
392 N.W.2d 493 (1986)
- Written by Liz Nakamura, JD
Facts
Paula McKee (defendant) was accused of intentionally physically abusing a resident at Woodward State Health Care Facility (Woodward), a mental health hospital. McKee was a Woodward employee. The State of Iowa (plaintiff) submitted a trial information to the district court charging McKee with wanton neglect of a healthcare facility resident. Iowa’s wanton-neglect statute prohibited a person from “knowingly [acting] in a manner likely to be injurious to the physical, mental, or moral welfare” of a healthcare facility resident. McKee moved to dismiss the trial information, arguing that (1) Iowa’s wanton-neglect statute was unconstitutionally vague; and (2) the statute’s prohibition against intentionally injuring residents was difficult to apply in the context of a mental health hospital because employees often needed to physically restrain residents either in self-defense or to protect the resident. The district court dismissed the trial information, holding that the wanton-neglect statute was unconstitutionally vague because it contained ambiguous language and lacked specific enforcement standards. Iowa appealed.
Rule of Law
Issue
Holding and Reasoning (Schultz, J.)
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