State of Iowa v. Ronald Eugene Cooley

CourtSupreme Court of Iowa
DecidedMay 16, 2025
Docket23-1375
StatusPublished

This text of State of Iowa v. Ronald Eugene Cooley (State of Iowa v. Ronald Eugene Cooley) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Ronald Eugene Cooley, (iowa 2025).

Opinion

In the Iowa Supreme Court

No. 23–1375

Submitted April 16, 2025—Filed May 16, 2025

State of Iowa,

Appellee,

vs.

Ronald Eugene Cooley,

Appellant.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Linn County, Ian K. Thornhill,

judge.

A defendant seeks further review of a court of appeals decision affirming

his conviction for failing to fulfill his sex offender registration requirements.

Decision of Court of Appeals Vacated; District Court Judgment Reversed

and Case Remanded.

McDermott, J., delivered the opinion of the court, in which all justices

joined.

Thomas M. McIntee, Williamsburg, for appellant.

Brenna Bird, Attorney General, and Nicholas E. Siefert, Assistant Attorney

General, for appellee. 2

McDermott, Justice.

Iowa law requires sex offenders to register their address with their local

sheriff and, if they move, to “appear in person to notify the sheriff” of a change

in residence within five business days. Iowa Code § 692A.104(1)–(2) (2021). When

the county sheriff learned that sex offender Ronald Cooley had moved but had

not registered his new address, the State charged Cooley with a registration

violation. Cooley claimed that he appeared in person at the sheriff’s office to

change his address but that the sheriff’s office was closed in response to the

COVID-19 pandemic. The State conceded that the office was closed, but it argued

that Cooley was nonetheless required to register his address by calling a phone

number posted on the sheriff’s office door. The district court rejected Cooley’s

request that the jury instructions include the “appear in person” requirement,

and the jury convicted Cooley of a registration violation. In this appeal, we must

decide whether appearing in person is an essential element of the crime of failing

to register a change of address and, if so, whether the sheriff’s office could modify

that definition during the pandemic.

I.

In 1991, Cooley pleaded guilty to the offense of assault with intent to

commit sexual abuse. This conviction later subjected Cooley to Iowa’s sex

offender registration requirements. See Iowa Code §§ 692A.102(1)(b)(6), .103(1).

In early January 2021, Cooley moved to Marion in Linn County. Upon

establishing his residence, Cooley had to register his address with the Linn

County Sheriff’s Office. See id. § 692A.104(1). Section 692A.104 states in

relevant part:

1. A sex offender shall appear in person to register with the sheriff of each county where the offender has a residence, maintains employment, or is in attendance as a student, within five business 3

days of being required to register under section 692A.103 by providing all relevant information to the sheriff. . . .

2. A sex offender shall, within five business days of changing a residence, employment, or attendance as a student, appear in person to notify the sheriff of each county where a change has occurred.

Id. § 692A.104(1)–(2).

But in January, and for many months after, the Linn County Sheriff’s

Office remained closed to the public in response to the COVID-19 pandemic. The

sheriff posted a large sign outside the building stating that the building was

closed and that anyone who needed to contact the sheriff’s office about the sex

offender registry could call during business hours.

In early January, Cooley drove to the sheriff’s office to register his address

and learned that the office was closed. He saw the sign about the building’s

closure and the phone number to call. According to Cooley, his experience with

the phone system was far from smooth. He claims that over the next few days,

he called about twice a day but never reached anyone. He said that the number

required him to navigate a series of prompts, but regardless of the prompt he

chose, he could not get through to a human. The sheriff, for his part, claims to

have had several secretaries within the office answering calls through four

different phone lines and that no other callers reported problems. If someone

called after hours, the phone system would route them to a dispatcher who

would tell the caller to try again during normal business hours.

Despite his claimed difficulties, Cooley ultimately succeeded on January

11 in registering the address for his apartment in Marion by telephone. In late

February, Cooley called the sheriff’s office again and spoke with a representative

to verify his information. 4

On April 14, a sergeant from the sheriff’s office went to the Marion

apartment to verify that Cooley lived there. The apartment was vacant. The

sergeant soon learned that about a month earlier, the tenant with whom Cooley

claimed to be cohabiting received a notice to vacate the apartment by March 30.

The sheriff’s office concluded that Cooley had failed to register his new address

within five business days as required in § 692A.104(2).

According to Cooley, he moved from the Marion apartment to a new

apartment in Cedar Rapids around April 1. Cooley claims that shortly after, he

drove to the sheriff’s office with a friend to register his new address in person but

that the sheriff’s office was still closed. Over the course of about a week,

according to Cooley, he tried calling the sheriff’s office number but again could

not get through. He eventually connected by phone with an assistant who

updated his address. Although the record is unclear what date this occurred, it

is undisputed that it was beyond five business days from when he vacated the

Marion apartment.

The State charged Cooley with two registration violations: falsely claiming

to reside at the Marion apartment (count I), and failing to register his new

address in Cedar Rapids within five business days (count II). The State also

sought a habitual offender enhancement against Cooley under Iowa Code

§ 902.8. The jury ultimately acquitted Cooley of count I (that he did not actually

reside at the Marion apartment), and we discuss it here no further.

Concerning the change-of-address violation, at the close of the State’s

evidence, Cooley moved for a judgment of acquittal, arguing that he complied

with § 692A.104(2)’s requirement to “appear in person” within five business days

of moving to Cedar Rapids to register his new address. The State argued that the

closure of the sheriff’s office in response to the pandemic did not eliminate 5

Cooley’s duty to register his new address because he could accomplish it by

phone.

The district court agreed with the State and denied the motion, concluding

that because Cooley was permitted to register by phone and not in person, he

suffered no prejudice. The court noted that during the office’s closure,

“the requirement to register actually became less onerous, not more.” The district

court similarly declined to grant an acquittal when Cooley renewed his motion

at the close of his case.

Cooley then requested that the district court include language in its

marshaling instruction that tracks § 692A.104(2)’s requirement that he “appear

in person” to register the new address. The district court rejected Cooley’s

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State of Iowa v. Ronald Eugene Cooley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-ronald-eugene-cooley-iowa-2025.