State of Iowa v. Justice Mathis

Summary

The Iowa Supreme Court reviewed Justice Mathis’s convictions for three counts of second-degree sexual abuse. The court held that sufficient evidence supported the convictions but that the jury instruction stating that the alleged victims’ testimony did not require corroboration improperly emphasized their testimony. Because the error was presumptively prejudicial and was not affirmatively shown to be harmless, the court vacated the court of appeals decision and district court judgment and remanded the case.

Holdings

1. Substantial evidence supported Mathis's convictions because B.T. and L.S. testified to specific sex acts performed by Mathis while they were under twelve years old, satisfying the elements in the marshaling instructions.
2. The instruction that there is no requirement that an alleged sexual-offense victim's testimony be corroborated did not violate Iowa Code section 709.6.
3. The instruction was improper because it singled out the alleged victims' testimony as not requiring corroboration without a symmetrical instruction concerning the defendant's testimony or a universal instruction concerning all witnesses.
4. The instructional error was prejudicial and required reversal because the record did not affirmatively establish the absence of prejudice, the children's testimony lacked corroboration, and the prosecutor made the noncorroboration instruction a focal point of closing argument.

Questions Presented

1. Whether substantial evidence supported Mathis's convictions for three counts of second-degree sexual abuse.
2. Whether the district court improperly instructed the jury that the testimony of an alleged victim of sexual offenses need not be corroborated.
3. Whether the erroneous noncorroboration instruction was prejudicial and required reversal of the convictions.

Disposition

reversed_and_remanded