The Court also addressed the issue of corporal punishment:



STATE V. MAGNESON



THE ISSUE:

Was the defendant merely punishing his 9-year-old son, or was it criminal child endangerment?



THE FACTS:

"The counts resulted from two incidents at a Des Moines hospital where Magneson was visiting a friend. He became unhappy when J.M. wished to visit one of his own friends who apparently was also there. The first incident occurred outside the surgical intensive care unit where Magneson became furious with J.M. and yelled at him to “sit the fuck down and stay the fuck there.” Magneson grabbed the crying child by his arms and three times forcefully pushed him down to the floor. J.M. kept getting up and called out, “No, Dad, stop. You always hit me.” The third time J.M. got up Magneson pushed him into the wall and said, “We’re going to leave and I’m going to beat your ass.” J.M. was very scared and upset and, according to the State’s witnesses, the confrontation left red marks on J.M.’s biceps.



The second incident occurred after Magneson did start to leave the hospital. Magneson shoved a nurse aside, grabbed J.M.’s arm and “whipped” him into a wooden guardrail using even more force than he had used in the first incident. The force caused J.M. to hit the side of his head on a rail, fall to the floor, and curl “up in a fetal position,” crying. As this happened J.M. again protested, “Quit hitting me, you always hit me.” Magneson again denied he was hitting him and warned him about what would happen when they got to the car."



THE RULING

"Iowa law “recognizes parents have a right to inflict corporal punishment on their child, but that right is restricted by moderation and reasonableness.” State v. Arnold, 543 N.W.2d 600, 603 (Iowa 1996); see also Hildreth v. Iowa Dep’t of Human Servs., 550 N.W.2d 157, 159 (Iowa 1996). Corrective discipline “must be for the purpose of behavior modification rather than to satisfy the passions of an enraged parent.” Arnold, 543 N.W.2d at 603. Whether a parent’s conduct goes beyond reasonable correction depends on whether “the amount of force used or the means employed by the parent rendered such punishment abusive rather than corrective in character.” Id. A determination of reasonableness varies with a child’s age, physical condition, and the nature of the child’s misconduct. Id. The evidence here, taken in the light most consistent with the verdict, justifies a jury finding that the punishment inflicted by Magneson was unreasonable, was a reaction to his own passions and anger, and was not a reasonable attempt to modify J.M.’s behavior."