State of Iowa v. Daniel Logan Walden, 2015 Iowa Sup. LEXIS 91

In 2006–2007, K.R., then about six, alleges Daniel Walden locked her in his bedroom and sexually molested her; she disclosed the abuse in 2014 at age 14.
Walden was arrested May 9, 2014 and charged (trial information) with first‑degree kidnapping (intent to commit sexual abuse), two counts of sexual abuse (second degree), and indecent contact with a child.
Walden moved to dismiss the first‑degree kidnapping count as time‑barred under the general three‑year felony statute of limitations (Iowa Code § 802.3 (2007)); the State argued the ten‑year extension for sexual abuse of minors (Iowa Code § 802.2(1) (2007)) applied.
The district court denied the motion, concluding the ten‑year limitations period governed; Walden sought discretionary review.
The Iowa Supreme Court reviewed statutory interpretation de novo, focusing on the plain text of §§ 802.2 and 802.3 and principles favoring repose in criminal limitations statutes.
The court reversed: because kidnapping is not among the exceptions enumerated in § 802.3 and § 802.2(1) applies only to prosecutions "for sexual abuse," the first‑degree kidnapping count was time‑barred; remaining sexual‑abuse and indecent‑contact counts could proceed.

Issue	State's Argument	Walden's Argument	Held
Which statute of limitations applies to first‑degree kidnapping with intent to commit sexual abuse of a minor?	§ 802.2(1) (10‑year post‑minority) applies because sexual abuse is a lesser included offense and the extended period should cover the greater charge tied to that abuse.	§ 802.3 (general 3‑year felony period) controls because kidnapping is not listed among the enumerated exceptions; omission is dispositive.	§ 802.3 governs; kidnapping is time‑barred. The court reversed dismissal denial and ordered the kidnapping count dismissed.

Toussie v. United States, 397 U.S. 112 (explaining purposes of criminal statutes of limitations favor repose)
State v. Robinson, 859 N.W.2d 464 (Iowa 2015) (kidnapping requires confinement/removal beyond that incidental to sexual abuse)
State v. Rich, 305 N.W.2d 739 (Iowa 1981) (legislature intended kidnapping to require more than incidental confinement in sexual‑assault cases)
State v. Whitfield, 315 N.W.2d 753 (Iowa 1982) (sexual abuse may be a lesser included offense of kidnapping)
Sherwin‑Williams Co. v. Iowa Dep’t of Revenue, 789 N.W.2d 417 (Iowa 2010) (absurd‑results doctrine should be used sparingly)
Stogner v. California, 539 U.S. 607 (limitations and ex post facto principles)
State v. Francois, 577 N.W.2d 417 (Iowa 1998) (criminal limitations statutes to be liberally construed in favor of repose)