State of Iowa v. Donald Lyle Clark
2012 Iowa Sup. LEXIS 60
| Iowa | 2012Background
- Clark was convicted of second-degree sexual abuse of a fifth-grade student (C.B.) during the 2003-2004 school year while Clark was a school guidance counselor.
- The State disclosed an email written by C.B. that described the alleged abuse only days before trial, after depositions had occurred.
- Clark sought a continuance, additional depositions, and production of an unredacted version of the email, arguing due process and right to present a defense.
- The district court ordered full email production but denied continuances and redepositions; trial proceeded with cross-examination focusing on credibility.
- Clark was convicted and sentenced to an indeterminate term not to exceed 25 years, with 70% to be served. A cross-appeal led to a Court of Appeals decision affirming the conviction, later granted for review by the supreme court.
- Dissent argued the denial of a brief continuance and failure to allow post-disclosure redepositions violated due process and the right to effective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to present a defense vs. discovery | Clark | State | No due process violation; no right to depose; continuance not required |
| Continuance after late email disclosure | Clark | State | No abuse of discretion; limited prejudice; information not material |
| Redepositions of witnesses after disclosure | Clark | State | No right to redepose; decision within trial court discretion |
| Iowa Brady-like disclosure impact | Clark | State | Late disclosure did not deprive fair trial; no prejudice shown |
| Ineffective assistance of counsel on direct appeal | Clark | State | Record insufficient; postconviction relief appropriate |
Key Cases Cited
- State v. Artzer, 609 N.W.2d 526 (Iowa 2000) (abuse-of-discretion standard for continuances)
- State v. Cashen, 789 N.W.2d 400 (Iowa 2010) (de novo review for present defenses and related claims)
- State v. Lyman, 776 N.W.2d 865 (Iowa 2010) (de novo review and defense presentation)
- State v. Piper, 663 N.W.2d 894 (Iowa 2003) (late disclosure and prejudice framework)
- Gambell v. State, 262 N.W.2d 792 (Iowa 1978) (depositions and effective assistance concerns)
- Osborn v. State, 573 N.W.2d 917 (Iowa 1998) (right to present a defense; due process)