State v. Woods

The defendant was convicted of possession of a controlled substance and carrying a dangerous weapon while in the illegal possession of a controlled substance or while committing an indictable offense. The Iowa Supreme Court held that the defendant’s conviction did not violate the Second Amendment nor the state constitutional right to keep and bear arms under art. 1, § 1A. For the Second Amendment analysis, the court found that historical analogues, such as laws enhancing penalties for crimes committed with firearms, supported the constitutionality of the statute. Regarding the state constitutional right, the court held that the statute survived strict scrutiny because it served a compelling state interest in public safety and was narrowly tailored to apply only when a person is simultaneously carrying a firearm and committing an indictable offense or illegally possessing a controlled substance.