State of Iowa v. Nathan Cole Bahr
CourtCourt of Appeals of Iowa
Date FiledMay 27, 2026
Docket24-1477
StatusPublished
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Full Opinion
IN THE COURT OF APPEALS OF IOWA
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No. 24-1477
Filed May 27, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Nathan Cole Bahr,
Defendant–Appellant.
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Appeal from the Iowa District Court for Hardin County,
The Honorable John R. Flynn, Judge.
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AFFIRMED
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Martha J. Lucey, State Appellate Defender, and Mary K. Conroy, Assistant
Appellate Defender, attorneys for appellant.
Brenna Bird, Attorney General, and David Banta, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Tabor, C.J., Langholz, J., and Vogel, S.J.
Opinion by Vogel, S.J.
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VOGEL, Senior Judge.
In 2023, Nathan Bahr was charged with the first-degree murder of his
ex-girlfriend. The case proceeded to trial. During jury selection, the State
moved to dismiss a juror for cause after the juror disclosed that he had been
both the aggressor and victim in a physically abusive romantic relationship
several decades earlier. Bahr resisted, arguing that sufficient time had passed
since the relationship ended such that the juror would be able to serve
impartially. The district court granted the State’s motion and dismissed the
juror for cause. After the case was submitted to the jury, it found Bahr guilty
as charged.
Bahr appeals, arguing the district court abused its discretion by
dismissing the juror without the State establishing a qualifying basis for
dismissal. The district court is vested with broad discretion in ruling on juror
challenges, and we review such rulings for an abuse of discretion. State v.
Jonas, 904 N.W.2d 566, 570–71 (Iowa 2017). However, as explained in State
v. Booker, even if the district court erroneously granted the for-cause strike,
it does not constitute reversible error unless Bahr can establish prejudice by
showing “the resulting jury was not impartial and competent.” 989 N.W.2d
621, 633 (Iowa 2023) (citation omitted). Bahr claims he was prejudiced
because the State had disproportionate power to shape the jury composition,
but he does not allege that the selected jury was partial or incompetent.
Because Bahr has not shown the requisite prejudice, his claim fails. Id. at
634.
Bahr argues that Booker should be overruled, a claim he did not make
to the district court. That issue is therefore not preserved for our review. See
State v. Crawford, 972 N.W.2d 189, 198 (Iowa 2022) (“[A] party has an
obligation to raise an issue in the district court and obtain a decision on the
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issue so that an appellate court can review the merits of the decision actually
rendered.”). Even if Bahr had preserved error on this argument, “we are not
at liberty to overrule controlling supreme court precedent.” State v. Beck, 854
N.W.2d 56, 64 (Iowa Ct. App. 2014) (cleaned up). We therefore affirm.
AFFIRMED.
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