State v. Striggles

210 N.W. 137 (1926)

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State v. Striggles

Iowa Supreme Court
210 N.W. 137 (1926)

Facts

Iowa law prohibited willfully having a commercial establishment that allowed gambling. A municipal court evaluated a particular gum- or mint-vending machine and ruled that the machine was not a gambling device. The machine’s distributors asked D. T. Striggles (defendant) to allow them to place one of the vending machines in his restaurant and showed him the municipal court’s ruling as proof that the machine was legal. Relying on the court ruling, Striggles allowed the machine to be installed and used in his restaurant. Later, the Iowa Supreme Court determined that the machine was a gambling device, and Striggles was criminally charged with having willfully allowed gambling on the machine in his restaurant. At trial, the court did not allow Striggles to introduce evidence of the municipal court order stating that the machine was legal. Striggles was convicted and fined. On appeal, the Iowa Supreme Court evaluated whether Striggles should have been allowed to introduce evidence of the municipal court’s order either to (1) establish a mistake-of-law defense or (2) show that he lacked any intent to commit an illegal act.

Rule of Law

Issue

Holding and Reasoning (Albert, J.)

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