## Facts

- A gum- or mint-vending machine was installed in various Des Moines businesses; the Iowa Supreme Court had previously determined this type of machine was a gambling device prohibited by statute.
- A Des Moines municipal court later issued a judgment stating the machine was not a gambling device.
- Distributors showed Striggles, a restaurant operator, a certified copy of the municipal court judgment and letters from the county attorney and the mayor stating the machine was not a gambling device, and Striggles allowed the machine to be installed in his restaurant.
- Striggles was indicted for willfully keeping a place resorted to for gambling and willfully permitting persons to gamble by means of the machine.
- At trial, the court excluded the municipal court judgment and the officials’ letters and limited Striggles’s testimony about relying on those documents to permit installation of the machine.
- Striggles was convicted and fined, and he appealed.

## Issues

1. Whether a prior municipal court judgment that the machine was not a gambling device barred a later prosecution for keeping a gambling place and permitting gambling using that machine.
2. Whether the municipal court judgment and letters from local officials were admissible to establish a defense based on reliance on official assurances or to negate the “willful” element of the charged offenses.

## Decision

- The Iowa Supreme Court affirmed the conviction.
- The municipal court judgment did not constitute a bar to prosecution and did not provide a defense.
- The excluded documents and related reliance testimony were not admissible to establish a legally recognized defense or to defeat the statutory “willful” requirement.

## Legal Principles

- A prior determination by an inferior court that certain conduct or a device is lawful does not preclude a later criminal prosecution under the controlling interpretation of state law.
- Mistake or ignorance of law is not a defense to criminal liability for keeping a gambling place and permitting gambling.
- Reliance on statements or letters from local officials (including a county attorney or mayor) does not immunize conduct that state law, as authoritatively interpreted, makes criminal.
- Evidence offered solely to show reliance on erroneous legal assurances may be excluded when it does not negate an element in a legally cognizable way.

## Conclusion

The court held that Striggles could not avoid liability for willfully keeping a gambling place and permitting gambling by pointing to a municipal court ruling and local officials’ assurances that the machine was lawful, and it affirmed his conviction.


State v. Striggles, 210 N.W. 137 (Iowa 1926)