105 Iowa L. Rev. 2359 (2020)

Download PDF

Abstract

In State v. Wilson, an Iowa district court found that a provision in Iowa’s recently enacted stand-your-ground law, Iowa Code section 704.13, was unconstitutionally vague. This decision constituted an unusual application of the void-for-vagueness doctrine because courts seldom consider vagueness challenges to statutory defenses and rarely, if ever, strike them down under such challenges. On appeal, the Iowa Supreme Court did not explicitly address the district court’s unusual holding that Iowa Code section 704.13 was void for vagueness. As a result, Wilson raises the following question: Is the void-for-vagueness doctrine an appropriate remedy for ambiguous statutory defenses? To answer this question, this Note examines traditional rationales underlying the void-for-vagueness doctrine. It also explores the potential expansion of the void-for-vagueness doctrine in the U.S. Supreme Court’s recent decisions. Ultimately, this Note concludes that the void-for-vagueness doctrine is not an appropriate remedy for ambiguous statutory defenses.