State of Iowa v. Alexander Shantee Thomas Ross, 986 N.W.2d 581

Defendant Alexander Ross was tried in March 2020 for two counts of second-degree sexual abuse based solely on the testimony of two stepdaughters (L.C. and K.C.); no physical or independent corroborating evidence was offered.
The district court, over defense objection, gave two nearly identical three-sentence noncorroboration instructions (one for each child): (1) evaluate the child’s testimony like any other witness; (2) the law does not require the child’s testimony be corroborated; and (3) you may convict if that testimony convinces you beyond a reasonable doubt.
The jury convicted on both counts; Ross received lengthy prison terms and a lifetime special sentence; he appealed claiming insufficient evidence, improper sentencing factor, and erroneous noncorroboration instructions.
The Iowa Court of Appeals reversed the convictions on the instruction error (relying on State v. Kraai and State v. Mathis); the State sought further review by the Iowa Supreme Court.
The Iowa Supreme Court affirmed the court of appeals: it held the particularized noncorroboration instructions improperly highlighted the victims’ testimony and, given the prosecution’s case relied entirely on that testimony, the presumption of prejudice was not overcome; convictions vacated and case remanded for retrial.
A dissent would have affirmed, arguing the three-sentence form cured asymmetry, the evidence was strong, and any error was harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Propriety of the three-sentence noncorroboration instruction	Instruction’s first and third sentences prevent singling out victims; instruction corrects common juror misconception	Instruction still particularizes and emphasizes victims’ testimony and omits that noncorroboration applies to all witnesses	Instruction was improper: asymmetrical and highlighted victims’ testimony; not cured by other instructions
Whether the instructional error was prejudicial (need for new trial)	Any error was harmless because evidence of guilt was sufficient / strong	Error likely prejudiced jury because State’s case depended entirely on uncorroborated victim testimony	Presumption of prejudice not overcome; new trial required
Sufficiency of the evidence to support convictions	Victim testimony was sufficient to sustain convictions	Evidence insufficient absent corroboration	Court left court-of-appeals ruling on sufficiency intact: evidence sufficient to sustain convictions (but convictions vacated on instruction error)
Consideration of sentencing challenge on appeal	(State) N/A	Ross argued improper sentencing factor	Supreme Court declined to consider sentencing challenge because case remanded for new trial

State v. Kraai, 969 N.W.2d 487 (Iowa 2022) (held a truncated noncorroboration instruction improperly emphasized complainant testimony and may mislead jurors)
State v. Mathis, 971 N.W.2d 514 (Iowa 2022) (applied Kraai where uncorroborated child testimony was the focal point and reversal was required)
State v. Donahue, 957 N.W.2d 1 (Iowa 2021) (standard for reviewing jury-instruction errors and when prejudice is presumed)
State v. Kennedy, 846 N.W.2d 517 (Iowa 2014) (inquiry into whether verdict actually rested on the error)
State v. Plain, 898 N.W.2d 801 (Iowa 2017) (prejudice test for nonconstitutional instructional errors)
State v. Rohm, 609 N.W.2d 504 (Iowa 2000) (instructions reviewed as a whole and judged in context)