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State v. Freeman | 450 N.W.2d 826 (1990)
Most criminal offenses require both an actus reus, or voluntary act or omission, and mens rea, or a guilty mind. In State versus Freeman, we explore mistake of fact as a means of negating mens rea.
Robert Freeman sold two grams of supposed cocaine to Keith Hatcher. Hatcher was working with law enforcement, and the sale therefore led to Freeman’s arrest. To everyone’s surprise, including Freeman’s, the substance was in fact acetaminophen, which wasn’t a controlled substance. Freeman was charged with delivering a simulated controlled substance in violation of Iowa law.
The trial court convicted Freeman. Freeman appealed to the Iowa Supreme Court, arguing that he couldn’t be liable for delivering a simulated controlled substance when he believed he was delivering an actual controlled substance.
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