UPDATES & ANALYSIS

3.13

Iowa Supreme Court affirms woman’s conviction for making terrorism threats

by Rox Laird | March 13, 2026

A Guthrie County woman made statements to her son that he interpreted as serious threats of violence against a Department of Health and Human Services child protective worker and a judge six days ahead of a hearing regarding the Department’s removal of her minor children from her care. His concerns were reported to law enforcement, and she was subsequently convicted on one count of threat of terrorism under Iowa Code Chapter 708A.

The woman, Alicia Fredericksen, raised three arguments on appeal to the Iowa Supreme Court: Her statements were “hypothetical” or “mere fantasies” and did not cause a “reasonable expectation of fear” required under Section 708A.5; statements she made six days before the scheduled hearing were not “imminent” threats; and her threats did not constitute “terrorism” under Section 708A.1(3).

The Iowa Supreme Court disagreed with all three arguments in a Feb. 27 decision written by Chief Justice Susan Christensen joined by all members of the Court.

Fredericksen made statements to her adult son that she had fantasized about torturing the HHS worker assigned to the case by cutting off the caseworker’s fingers and beating her until she was physically incapacitated. Fredericksen also told her son she was going to shoot and kill the judge assigned to the case and the HHS worker when they were in court.

“This appeal turns on whether such a threat—specific in its targets, explicit in its violence, and tethered to a fixed court date—is ‘imminent’ and constitutes a threat of terrorism under Iowa Code section 708A.5 (2024),” Chief Justice Christensen wrote. “Under these circumstances, yes. It does.”

Chapter 708A, Iowa’s terrorism statute, does not define “threat” or “reasonable expectation or fear,” but the Iowa Supreme Court in previous cases has applied the common meaning of the words to mean they are “a promise or expression of intent to inflict distress, evil, injury, or damage on another” and are “understandable as a threat by a reasonable person of ordinary intelligence.”

In this case, the Court concluded there was sufficient evidence to support Fredericksen’s conviction for making a threat based on explicit statements made to her son—who had knowledge of his mother’s temperament and understood her statements as true threats—about her plans to torture the HHS worker before shooting the caseworker as well as the judge at the court hearing. In addition, two other witnesses understood Fredericksen’s threats as expressions of her intent to harm the professionals involved in her juvenile court case, the Iowa Supreme Court said.

Fredericksen argued there was insufficient evidence to prove she would “imminently” act on her threats because she made them six days before the hearing. The Iowa Supreme Court disagreed.

Chapter 708A does not define “imminent,” so the Court has previously relied on the dictionary definition of the word as “ready to take place,” “near at hand,” “hanging threateningly over one’s head,” and “menacingly near.” While the statute does not require a person to threaten the immediate commission of an act of terrorism, the Court said in a 2006 decision, “it does require a reasonable expectation the act is impending or about to occur.”

Under the totality of the circumstances, the Court said, Fredericksen’s threats created a reasonable expectation or fear that her carrying them out was imminent. “Fredericksen’s threats involved a specific date on which she indicated she would act on them, and that date was the scheduled August 9 hearing when she would be in the same room as the targets of her threats.”

Finally, the Court disagreed with Fredericksen’s argument that her threats did not constitute terrorism under Chapter 708A, which defines terrorism in relevant part as an act “intended to intimidate or coerce a civilian population, or to influence the policy of a unit of government by intimidation or coercion, or to affect the conduct of a unit of government, by shooting, throwing, launching, discharging, or otherwise using a dangerous weapon at, into, or in a building, vehicle, airplane, railroad engine, railroad car, or boat, occupied by another person, or within an assembly of people.”

Fredericksen contended her threats did not rise to that level because she made them to her son and had not intended they would be relayed to HHS or to the judge in the juvenile court case to influence their conduct in the case. But the statute does not require an intent on Fredericksen’s part that her threats be communicated to her intended targets, Chief Justice Christensen wrote.

“Because Fredericksen’s threats suggest that the objective of her threatened acts would be to exact vengeance or retaliation on two individuals who could steer the outcome of the upcoming juvenile court hearing,” she wrote, “it was not unreasonable for the district court to conclude Fredericksen threatened to commit an act of terrorism that would ‘affect the conduct of a unit of government,’ i.e., the court proceeding in her juvenile court case.”

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The Iowa Supreme Court entered opinions in ten cases in January 2026. On Brief has analyzed three opinions in separate posts. The remaining opinions from January are summarized below.

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