State of Iowa v. Benjamin G. Trane, 984 N.W.2d 429

Background

Benjamin Trane ran a school for troubled youth; in 2015 the State charged him with sexual abuse, sexual exploitation by a counselor/therapist, and child endangerment based on allegations by a female, K.S.
A jury convicted Trane on three counts, including assault with intent to commit sexual abuse; Trane moved for a new trial, seeking to admit evidence that K.S. previously made false sexual‑abuse accusations against adoptive/foster parents.
On direct appeal this Court conditionally remanded for an in camera Iowa R. Evid. 5.412 hearing to determine, by a preponderance, whether K.S. had made false allegations against her adoptive or foster parents (Trane I). If so, Trane would be entitled to a new trial.
At the remand 5.412 hearing K.S. testified she was sexually abused by her adoptive father; her deposition (offered by Trane) contained similar statements. K.S.’s adoptive parents denied any physical or sexual abuse.
The district court ruled Trane failed to prove, by a preponderance, that K.S. made false allegations and denied a new trial. Trane appealed, arguing (inter alia) the judge should have recused, the court improperly considered certain evidence, and the court erred in finding insufficient proof of falsity.
The Iowa Supreme Court affirmed, holding the district court did not abuse its discretion on recusal, evidentiary preservation, or in concluding Trane failed to meet his burden under Rule 5.412.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Recusal of remand judge	Judge’s prior conduct created reasonable doubt about impartiality; recusal required	Judge’s rulings and courtroom demeanor arose from participation in the case, not extrajudicial bias	Court: no abuse of discretion; no extrajudicial personal bias shown; motion properly denied
Consideration of evidence beyond sexual‑abuse allegations (physical abuse, adoptive mother’s knowledge, prior trial testimony)	Such evidence was outside scope of remand and Rule 5.412 and should not have been considered	State: these matters were raised or otherwise before the court; consideration was proper	Court: Trane waived objections by introducing/eliciting much of that evidence and failing to preserve objections; appellate review declined
Preservation of evidentiary objections	Certain uses of pretrial and prior‑trial testimony were judicial error	Trane failed to object or obtain rulings and did not move for reconsideration after the ruling	Court: objections were not preserved; error review forfeited under preservation rules
Sufficiency under Iowa R. Evid. 5.412 (did Trane prove prior false accusations?)	K.S.’s testimony was unreliable and inconsistent; multiple accusations against others undermined credibility; court should have found falsity	K.S.’s live and deposition testimony that she was abused constituted substantial evidence refuting falsity; credibility is for factfinder	Court: no abuse of discretion; district court reasonably credited K.S.; Trane failed to prove falsity by preponderance

Key Cases Cited

State v. Trane, 934 N.W.2d 447 (Iowa 2019) (remand directing in camera Rule 5.412 hearing)
Carter v. Carter, 957 N.W.2d 623 (Iowa 2021) (recusal standard; objective test and requirement of actual prejudice)
Millsap v. State, 704 N.W.2d 426 (Iowa 2005) (disqualifying bias must stem from extrajudicial source)
Biddle v. State, 652 N.W.2d 191 (Iowa 2002) (burden on party seeking recusal)
Alberts v. State, 722 N.W.2d 402 (Iowa 2006) (abuse‑of‑discretion standard for Rule 5.412 determinations)
State v. Mathis, 971 N.W.2d 514 (Iowa 2022) (deference to factfinder; criticism of isolated precedent undermining credibility review)
State v. Wells, 629 N.W.2d 346 (Iowa 2001) (deference to factfinder on credibility)
United States v. Kime, 99 F.3d 870 (8th Cir. 1996) (district court credibility findings are virtually unreviewable)