State of Iowa v. Kurt Allen Kraai, 969 N.W.2d 487

Kurt Kraai was convicted of second-degree sexual abuse based on his daughter N.F.'s testimony and his denial at trial.
The district court instructed the jury: “There is no requirement that the testimony of a complainant of sexual offenses be corroborated.” Kraai objected, citing Iowa Code § 709.6.
Kraai argued the instruction violated § 709.6 and unduly emphasized the complainant’s testimony by singling it out. The State argued the instruction correctly stated the law and countered jurors hold misconceptions requiring dispelling.
Physical evidence seized at Kraai’s home corroborated parts of N.F.’s account: pornographic material in living areas, blue flannel pajama pants with a crotch hole, and photographs showing a silver ring on Kraai’s penis matching N.F.’s description.
The court of appeals deemed the instruction erroneous but harmless; the Iowa Supreme Court reviewed whether the instruction violated the statute or impermissibly emphasized the victim’s testimony and whether the error was prejudicial.

Issue	State's Argument	Kraai's Argument	Held
Whether the asymmetrical noncorroboration instruction violated Iowa Code § 709.6	Instruction accurately states law that a victim’s testimony need not be corroborated and dispels juror misconceptions	Instruction singled out the victim and thus used a different standard for her testimony in violation of § 709.6	No statutory violation: the statement of law was accurate and not on its face forbidden by § 709.6
Whether giving the noncorroboration instruction (without a universal instruction) unduly emphasized the complainant’s testimony and required reversal	Instruction necessary to correct juror misconceptions; other general credibility and burden instructions cured any error	Instruction improperly highlighted N.F.’s testimony and risked giving it special weight; reversible unless harmless	Instruction was improper because it unduly emphasized the complainant; error was harmless given strong corroborative evidence and thus conviction affirmed

State v. Feddersen, 230 N.W.2d 510 (Iowa 1975) (abolished Lord Hale instruction requiring corroboration)
State v. Bester, 167 N.W.2d 705 (Iowa 1969) (error to single out witness credibility by special instruction)
State v. Nepple, 211 N.W.2d 330 (Iowa 1973) (credibility instructions must apply equally to all witnesses)
State v. Milliken, 204 N.W.2d 594 (Iowa 1973) (improper to give instructions that unduly emphasize specific evidentiary facts)
State v. Ludwig, 305 N.W.2d 511 (Iowa 1981) (credibility instruction acceptable when applied equally to all witnesses)
State v. Hildreth, 582 N.W.2d 167 (Iowa 1998) (victim’s testimony alone can constitute substantial evidence)
Gutierrez v. State, 177 So. 3d 226 (Fla. 2015) (asymmetrical no‑corroboration instruction improper because it emphasizes victim testimony)
State v. Plain, 898 N.W.2d 801 (Iowa 2017) (prejudice presumption for instruction error, reversible unless record shows no prejudice)
State v. Donahue, 957 N.W.2d 1 (Iowa 2021) (instructions reviewed as a whole for legal accuracy)