State of Iowa v. Benjamin G. Trane, 934 N.W.2d 447

Background

Benjamin Trane owned Midwest Academy, a private therapeutic boarding school that used restrictive "levels" and isolation OSS rooms; two boys (A.H., B.V.) were confined for long periods, suffered severe weight loss and related harms.
K.S., a 17-year-old student for whom Trane served as "family representative," accused Trane of multiple incidents of sexual contact; no independent witnesses corroborated these sexual allegations.
DHS, FBI, and DCI investigated; over 5 terabytes of discovery were produced shortly before trial; Trane received the materials on a newly purchased hard drive 14 days before trial.
On December 11, 2017 (the day before trial), a deposition of K.S. revealed she had previously accused adoptive and foster parents of sexual abuse; Trane filed a Rule 5.412 motion that evening seeking to admit evidence that those prior allegations were false.
The district court denied the Rule 5.412 motion as untimely and for lack of proof without holding an in camera hearing; jury convicted Trane of (1) assault with intent to commit sexual abuse (lesser included), (2) pattern/practice sexual exploitation by a counselor, and (3) child endangerment; defendant moved for new trial asserting, inter alia, ineffective assistance of counsel.
Iowa Supreme Court: affirmed convictions as supported by sufficient evidence, held district court erred by not conducting a Rule 5.412 hearing on whether K.S. made false prior allegations, and conditionally remanded for that hearing; ineffective-assistance claims should generally be developed in postconviction proceedings.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Trane)	Held
1. Exclusion of evidence of K.S.'s alleged prior false abuse reports without a Rule 5.412 hearing	Motion untimely, no written offer of proof, and allegations not recanted	Evidence was newly discovered at K.S.'s deposition; Rule 5.412 exception for false accusations applies and was necessary to impeach credibility	Court abused discretion by denying hearing; remanded for in camera Rule 5.412 hearing; if Trane proves falsity by preponderance, grant new trial; if not, convictions stand
2. Sufficiency of evidence on three counts	State: testimony (especially K.S.) and other evidence suffice for each charge	Trane: uncorroborated allegations and inconsistent evidence insufficient	Evidence was sufficient on all counts when viewed in State's favor; convictions may stand absent successful Rule 5.412 showing
3. Whether district court should consider ineffective-assistance claims on motion for new trial	Court may decline; statutory scheme channels most claims to PCR or direct appeal	Trane: district court should fully consider ineffective-assistance claims now	Court did not err in refusing to fully resolve ineffective-assistance claims on motion for new trial; such claims are typically for postconviction relief or direct appeal when record is adequate
4. Severance of sex-related counts from child-endangerment count	Joinder was permissible or any failure to move is procedural	Joinder prejudiced Trane; counts involved different victims and conduct and should have been severed	Not resolved on the merits—treated as part of ineffective-assistance arguments to be developed in PCR or direct appeal if record adequate
5. Expert testimony (Dr. Salter) allegedly vouching for victim credibility	Testimony provided general context about sexual abuse reporting; no contemporaneous objection	Testimony improperly vouched for K.S. and prejudiced the jury	Court did not rule processibly; absence of objection limits appellate relief; claim preserved for ineffective-assistance/PCR review
6. Jury instruction that used "and/or" regarding which child was endangered	Instruction adequately tracked charging theory	Instruction deprived Trane of unanimity as to a particular victim	Court expressed concern about the instruction’s form; the issue should be explored in ineffective-assistance proceedings; conviction stands absent Rule 5.412-based reversal

Key Cases Cited

State v. Alberts, 722 N.W.2d 402 (Iowa 2006) (requires in camera Rule 5.412 hearing and preponderance showing before admitting evidence of allegedly false sexual allegations)
State v. Baker, 679 N.W.2d 7 (Iowa 2004) (false allegation is not "sexual behavior" barred by rape-shield rule)
State v. Millam, 745 N.W.2d 719 (Iowa 2008) (failure to pursue Rule 5.412 evidence can constitute ineffective assistance)
Michigan v. Lucas, 500 U.S. 145 (1991) (upheld notice-and-hearing requirements for rape-shield exceptions as reasonable, subject to case-by-case balancing)
Nevada v. Jackson, 569 U.S. 505 (2013) (enforcement of rape-shield notice rules may be upheld on habeas where reasonable)
State v. Veal, 930 N.W.2d 319 (Iowa 2019) (court should balance speedy-trial rights against late-discovered pretrial motions and may grant limited continuance)
State v. Wickes, 910 N.W.2d 554 (Iowa 2018) (pattern/practice element for sexual exploitation offense explained)
State v. Ogilvie, 310 N.W.2d 192 (Iowa 1981) (purposes of rape-shield statutes include protecting victim privacy and encouraging reporting)