State of Iowa v. Michael John Alberts

Summary

The Iowa Supreme Court reviewed Michael John Alberts’s conviction for third-degree sexual abuse. The court held that the district court erred by excluding evidence concerning an alleged prior false claim of sexual misconduct arising from a skinny-dipping incident without first determining whether the statements were made and were false by a preponderance of the evidence. The court partially vacated the court of appeals decision and remanded for further proceedings.

Holdings

1. When a ruling on a motion in limine definitively determines that challenged evidence is inadmissible, the issue is preserved without a renewed objection when the evidence would have been offered at trial.
2. Skinny-dipping is not inherently sexual behavior, but the particular incident qualified as past sexual behavior because the surrounding circumstances indicated it was a precursor to sexual activity.
3. A criminal defendant seeking to introduce evidence that a complaining witness previously made a false claim of sexual misconduct must establish outside the presence of the jury, by a preponderance of the evidence, both that the witness made the statements and that the statements were false.
4. If the defendant satisfies the threshold falsity showing, the evidence is relevant to the complaining witness’s credibility and possible motive to lie, and the record did not show that its probative value was substantially outweighed by unfair prejudice or other Rule 5.403 dangers.
5. The trial court abused its discretion by excluding the evidence without allowing Alberts to establish whether R.M. made the alleged statements and whether they were false. The case must be remanded for that hearing; if Alberts satisfies the threshold, a new trial must be granted, and otherwise the conviction stands.

Questions Presented

1. Whether Alberts preserved his challenge to the exclusion of the skinny-dipping evidence when the district court definitively ruled on the State’s motion in limine.
2. Whether the skinny-dipping incident constituted the complaining witness’s past sexual behavior under Iowa’s rape-shield law.
3. Whether a defendant seeking to introduce an alleged prior false claim of sexual misconduct must make a threshold showing outside the presence of the jury that the complaining witness made the statements and that they were false.
4. Whether the excluded evidence was relevant and whether its probative value was substantially outweighed by unfair prejudice or other dangers under Iowa Rules of Evidence 5.401, 5.402, and 5.403.
5. Whether the district court’s failure to conduct the threshold hearing required remand for a hearing and possible new trial.

Disposition

reversed_and_remanded