State of Iowa v. Timothy Lee Hall Jr.

── State of Iowa v. Timothy Lee Hall Jr. ── Court: Supreme Court of Iowa Date: May 22, 2026 Category: General In the Iowa Supreme Court No. 25–0306 Submitted March 25, 2026—Filed May 22, 2026 State of Iowa, Appellee, vs. Timothy Lee Hall Jr., Appellant. Appeal from the Iowa District Court for Guthrie County, William A. Price, senior judge. A criminal defendant challenges his conviction of harassment in the second degree as well as the entry of a no-contact order. Affirmed. May, J., delivered the opinion of the court, in which all justices joined. Martha J. Lucey, State Appellate Defender, and Allison Linafelter and Corey Engle (until withdrawal), Assistant Appellate Defenders, for appellant. Brenna Bird, Attorney General, and David Banta, Assistant Attorney General, for appellee.  2 May, Justice. Timothy Hall Jr. appeals his conviction for harassment in the second degree and the entry of a no-contact order. Hall raises two arguments. First, Hall argues that he can’t be convicted of harassment because he didn’t initiate the encounter during which Hall harassed his victim. Second, Hall argues that his harassment conviction was not enough—on its own—to justify the entry of a no- contact order to protect Hall’s victim. We reject both of Hall’s arguments, and we affirm. I. Factual and Procedural Background. Like many Iowa communities, Guthrie Center has a Casey’s General Store. According to the evidence at trial, Hall visited that Casey’s on two consecutive days. During the first visit, Hall got into an argument with a woman in the parking lot. A Casey’s employee saw the argument and told her manager about it. The manager was Joshua Vanhorn. The next morning, Hall made his second visit. This time, Hall entered the Casey’s to purchase a beverage. An employee recognized Hall and alerted Vanhorn. Vanhorn approached Hall near the cooler doors in the back of the store. The two men stood about two feet away from one another. Vanhorn asked Hall to leave. But Hall did not immediately comply. Instead, Hall cursed at Vanhorn. Hall also threatened Vanhorn by saying something like, “Come outside and I’ll bust your lip.” Hall was still cursing when he finally left. Following an investigation, the Guthrie County Sheriff’s Department filed a complaint charging Hall with harassment in the second degree under Iowa Code sections 708.7(1)(b) and 708.7(3)(a) (2024). Soon after, the district court issued a temporary no-contact order that restrained Hall and protected Vanhorn.  3 Following a bench trial, Hall was convicted of harassment in the second degree. The same day, Hall was sentenced to one year in jail, suspended with probation. The sentencing order listed some specific conditions of probation. One of the conditions was: “Abide by the separate No Contact Order issued herein.” After the sentence was read, there was a break in the proceedings. Then the sentencing judge issued a new five-year no-contact order to Hall. The judge explained it this way: THE COURT: Mr. Hall, I handed you a no contact order between you and Joshua Vanhorn. That no contact order replaces the earlier no contact order. This is effective till February 17, 2030. Five years. And that’s no contact in person, by phone, in writing, voicemail, email, or through third parties. Joshua -- Joshua Vanhorn cannot give you permission to violate this order. If you have any contact with him in any way, you are subject to immediate arrest and could be ordered to jail for up to 180 days for each violation of the no contact order. That could also become a violation of your probation, causing