a single act or a series of acts to constitute a unit of prosecution for willful injury, then it certainly had the wherewithal to do so when drafting section 708.4(1). More complicating is the fact that our court has construed certain criminal statutes without express reference to a “series of acts” or a “course of conduct” to include a series of acts as a single unit of prosecution. Compare State v. Amsden, 300 N.W.2d 882, 887 (Iowa 1981) (finding the jury should have been instructed on the joinder of a series of acts in a theft case when the prosecution charged the defendant with one count of first-degree theft based on five separate acts, even though Iowa Code section 714.2 refers only to the “theft of property”), with State v. Melia, 231 Iowa 332, 339, 1 N.W.2d 230, 233 (1941) (<HOLDING>). When criminal statutes are ambiguous, we
recognizing high probative value of act done in furtherance of conspiracy because it is part of the very act charged holding that two entities were a single employer and therefore that their gross receipts could be totaled together to establish jurisdiction under the national labor relations act holding that the government did not have to prove that the defendant knew that his acts violated the clean water act but merely that he was aware of the conduct that resulted in the permits violation holding the defendants act of firing five shots very close together where two deaths resulted constituted not a single act but a series of acts holding that single substantial act can support exercise of personal jurisdiction