In the Interest of A.K., Minor Child A.K., Minor Child, 2013 Iowa Sup. LEXIS 2

A.J. 15-year-old A.K. was adjudicated delinquent on seven counts for sexual abuse and related assaults against three victims.
Adjudicatory hearing in January 2012 followed petitions filed Aug–Sep 2011; charges included three acts of sexual abuse in the second degree and four counts of assault with intent to commit sexual abuse.
D.E. testified that A.K. engaged in explicit sexual acts in the back of a car after a July 1, 2011 event at the county fairgrounds.
J.E. testified about another encounter at an abandoned house; K.D. testified to multiple incidents of rubbing and touching, three times.
A.K. did not testify; defense challenged credibility and asserted car location and other alibi evidence.
The juvenile court convicted on six counts and acquitted/failed to prove one count (J.E. count), leading to an appeal on evidentiary and sufficiency grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prior-bad-acts evidence was admissible	A.K. contends 5.404(b) material should have been excluded.	State argues relevance and admissibility support intent and pattern.	De novo review upheld admission not outcome-determinative.
Whether evidence proves all seven delinquency counts beyond a reasonable doubt	State claims three acts against D.E. and three acts against K.D. show sexual abuse/assault with intent.	A.K. challenges credibility and variances; defense asserts insufficiency for some counts.	Affirmed as to D.E. counts I–III and K.D. counts I–III; reversed as to J.E. count IV.

In re J.A.L., 694 N.W.2d 748 (Iowa 2005) (de novo standard for reviewing evidence in delinquency cases; admissibility of other-acts evidence)
State ex rel. Turner v. Younker Bros., Inc., 210 N.W.2d 550 (Iowa 1973) (review of facts and law anew; equity-based reasoning)
In re Marriage of Winegard, 257 N.W.2d 609 (Iowa 1977) (de novo standard; interpretation of equity and review scope)
Henderson v. State, 199 N.W.2d 111 (Iowa 1972) (juvenile proceedings are distinct; emphasis on best interests)
In re A.D., 771 A.2d 45 (Pa. Super. Ct. 2001) (sufficiency review in juvenile adjudication is substantial-evidence standard)
State v. Bash, 670 N.W.2d 135 (Iowa 2003) (conceptual discussion of sufficiency review framework in criminal contexts)
Kent v. United States, 383 U.S. 541 (1966) (juvenile rights and considerations; focus on welfare and due process)
McKeiver v. Pennsylvania, 403 U.S. 528 (1971) (no right to jury trial in juvenile proceedings; impact on fact finding)