State of Iowa v. Matthew Earl Cox

Summary

The Iowa Supreme Court considered whether evidence of the defendant’s prior sexual abuse of different victims was admissible under Iowa Code section 701.11. The court held that admitting such evidence solely to demonstrate propensity violated the due process clause of the Iowa Constitution because it was not relevant to a legitimate issue. The judgment was reversed and the case remanded.

Holdings

1. The Iowa Constitution's due process clause prohibits admission of prior sexual-abuse evidence involving a different victim when the evidence is admitted solely to demonstrate general propensity. Iowa Code section 701.11 was unconstitutional as applied to Cox because the State offered the evidence without establishing a legitimate non-propensity issue.
2. Prior sexual-abuse evidence involving a different victim may be admitted only when relevant and material to a legitimate issue other than general propensity, such as identity, intent, motive, or rebuttal of a specific defense, and when its probative value is not substantially outweighed by unfair prejudice.
3. The testimony from T.C. and A.L. was not relevant to a legitimate issue because the incidents were separate in time and place, did not establish a common scheme or plan, did not bear on identity or consent, and did not prove motive or intent required for the charged offenses.
4. Admission of the prior-abuse testimony was not harmless beyond a reasonable doubt because the testimony described a large number and variety of prior sexual-abuse acts and likely contributed to the verdict.

Questions Presented

1. Whether Iowa Code section 701.11 violates the due process clause of the Iowa Constitution when applied to admit prior sexual abuse involving victims other than the victim named in the charged offenses solely to demonstrate general propensity.
2. Whether the prior-abuse testimony from T.C. and A.L. was relevant to a legitimate non-propensity issue under Iowa Rule of Evidence 5.404(b), including common scheme or plan, modus operandi, opportunity, preparation, motive, or intent.
3. Whether admission of the prior-abuse testimony was harmless beyond a reasonable doubt.

Disposition

reversed_and_remanded