State of Iowa, 20-1282

State petitioned to civilly commit Zachary Welsh as a sexually violent predator under Iowa Code chapter 229A; Welsh was "presently confined" and does not dispute that status.
Uncontested criminal history: early onset (exposing himself from about age 10), juvenile adjudication for sexual assault, multiple adult convictions for indecent exposure, harassment (obscene calls), and sex-offender-registry violations including peering at dancers; many incidents span decades.
Welsh admitted to numerous uncharged exposures, failed to complete earlier sex-offender treatment, and testified he completed later treatment by lying.
Competing expert testimony: State psychologist diagnosed an impulse-control/hypersexual disorder, relied on actuarial tools, and opined Welsh is likely to reoffend; Welsh’s expert acknowledged disorders but concluded none met the statutory "mental abnormality" standard and noted long intervals since some offenses.
District court credited the State’s expert, found Welsh has "serious difficulty controlling his behavior," and committed him; appellate court reviewed sufficiency of evidence and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence showed Welsh has a qualifying mental abnormality causing serious difficulty controlling behavior (necessity for SVP commitment under the first course)	State: expert diagnosis + actuarial assessments + extensive sexual-offense history establish serious difficulty controlling impulses and high likelihood to reoffend	Welsh: gaps in recent sexual misconduct and expert opinion show no current qualifying mental abnormality	Court: Affirmed — substantial evidence supports finding of serious difficulty controlling behavior; credited State’s expert
Whether appellate court should overturn district court’s credibility choice between experts	State: deference to district court factfinding; credibility determinations control	Welsh: urges that expert conflict and elapsed time since some acts undercut sufficiency	Court: Defer to district court’s credibility determinations in a battle of experts; affirmation appropriate

In re Det. of Stenzel, 827 N.W.2d 690 (Iowa 2013) (discusses SVP elements and use of actuarial assessments alongside clinical judgment)
In re Det. of Betsworth, 711 N.W.2d 280 (Iowa 2006) (standard for reviewing sufficiency of evidence in SVP commitments)
In re Det. of Wygle, 910 N.W.2d 599 (Iowa 2018) (distinguishes commitment courses based on whether respondent is presently confined)
In re Det. of Swanson, 668 N.W.2d 570 (Iowa 2003) (on evaluating the sufficiency of evidence and reasonable inferences)
In re Det. of Altman, 723 N.W.2d 181 (Iowa 2006) (on deference to district court when weighing expert testimony)
State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (district court is in better position to assess witness credibility)