State of Iowa v. Ryan Dennis Meyer

• Court: Court of Appeals of Iowa
• Decided: October 1, 2025
• Docket: 24-1384
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1384 Filed October 1, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

RYAN DENNIS MEYER, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Mitchell County, Elizabeth Batey,

Judge.

A defendant challenges the sufficiency of the evidence supporting his

conviction for possession of marijuana. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg (until

withdrawal) and Shellie L. Knipfer, Assistant Appellate Defenders, for appellant.

Brenna Bird, Attorney General, and Katherine Wenman, Assistant Attorney

General, for appellee.

Considered without oral argument by Ahlers, P.J., and Chicchelly and

Sandy, JJ. 2

AHLERS, Presiding Judge.

While talking with Ryan Meyer at his apartment for an unrelated matter, a

police officer noticed the smell of marijuana coming from the apartment. The

officer later applied for and received a warrant to search Meyer’s apartment. The

subsequent search uncovered an ice cream bucket hidden in a kitchen cupboard.

Inside the bucket was a green leafy substance that smelled of marijuana and a

prescription pill bottle wrapped in duct tape. The pill bottle also smelled of

marijuana and contained a green leafy substance like that found in the bucket.

Testing confirmed that the green leafy substances were marijuana, so the State

charged Meyer with possession of marijuana. A jury found Meyer guilty, and he

was sentenced accordingly.

Meyer appeals. He contends the evidence presented at trial was insufficient

to prove that the substance at issue was marijuana. In particular, he contends the

State failed to prove the substance was not hemp.

Sufficiency-of-the-evidence challenges are reviewed for correction of errors

at law. State v. Mathis, 971 N.W.2d 514, 516 (Iowa 2022). This standard is highly

deferential to the jury’s verdict, which we uphold if it is supported by substantial

evidence. Id. “Substantial evidence is evidence sufficient to convince a rational

trier of fact the defendant is guilty beyond a reasonable doubt.” Id. at 516–17. In

determining whether the verdict is supported by substantial evidence, we view the

evidence in the light most favorable to the State. Id. at 517. This includes resolving

all legitimate inferences and presumptions that may arise from the evidence in the

State’s favor. Id. 3

Meyer’s challenge is based on the hemp exception in the controlled-

substance statute. Iowa Code section 124.204(4)(m) (2023) identifies marijuana

as a schedule I controlled substance. However, the inclusion of marijuana as a

controlled substance is qualified with “except as otherwise provided in

subsection 7.” Iowa Code § 124.204(4)(m). Subsection 7 provides that

section 124.204—which defines schedule I controlled substances—does not apply

to hemp “with a maximum delta-9 tetrahydrocannabinol [THC] concentration that

does not exceed three-tenths of one percent on a dry weight basis.” Id.

§ 124.204(7)(a). Based on this exception, Meyer contends the State had to prove

the substance he possessed was not hemp by proving it had a THC concentration

that exceeded three-tenths of one percent. But Meyer’s contention overlooks

controlling case law.

In State v. Mumford, our supreme court rejected a similar argument.

14 N.W.3d 346, 356 (Iowa 2024). In that case, the court noted that the statute’s

exclusion of hemp from the definition of marijuana carved out an exception to a

marijuana offense. Id. But the court held that the State need not “disprove an

exception to a criminal offense unless a defendant produces evidence to put the

exception at issue.” Id. (quoting United State v. Rivera, 74 F.4th 134, 136 (3d Cir.

2023)). An exchange between the district court and Meyer’s counsel, after he

requested a jury instruction that would require the State to prove the substances

were not hemp, confirms his failure to produce such evidence:

DEFENSE COUNSEL: What . . . if it can be proven that it is hemp, then— THE COURT: So—so give me one piece of evidence that was offered that establishes that it is hemp. One piece of evidence that 4

is probative of that being hemp. Not just the possibility that it could be hemp, but that it is hemp. DEFENSE COUNSEL: That evidence hasn’t been—hasn’t been submitted, Your Honor.

As acknowledged by Meyer’s trial counsel, no evidence was presented that the

substances at issue were hemp. As such, the State was not required to prove that

the substances were not hemp, and Meyer’s challenge based on the hemp

exception fails. See id.

Before concluding, we also address Meyer’s argument that, because the

district court gave several jury instructions addressing hemp, the court must have

determined there was sufficient evidence to generate a jury question on the hemp

exception. To begin, we note that the marshaling instruction only required the

State to prove the substances were marijuana, with no mention of the hemp

exception. The two instructions that followed stated:

• “Marijuana, with the exception of hemp and hemp products, is a controlled

substance.”

• “It is not necessary for the State to prove that the exception for hemp and

hemp products does not apply, unless the defendant has first offered proof

that the exception does apply.”

Meyer raises no challenge to these or any other instructions on appeal. Instead,

he contends the two instructions establish that he generated a fact question over

the hemp exception. But this claim is belied by the district court’s explanation that

it included the instructions because Meyer’s counsel, through questioning, had

“muddied the waters” about hemp even though “there’s actually no evidence in our

record that the product is hemp.” The fact that Meyer’s questioning about hemp— 5

unsupported by evidence—necessitated the inclusion of clarifying instructions to

avoid confusing the jury in no way undermines our conclusion that the State was

not required to disprove the hemp exception.

As Meyer makes no sufficiency challenge beyond that related to the hemp

exception and we find that exception does not apply due to lack of evidence

supporting it, we affirm his conviction.

AFFIRMED.