State of Iowa v. Matthew Alan Kuester, 15-0650

Defendant Matthew Kuester was convicted by a jury of three counts of indecent exposure for masturbating in a truck parked on the University of Northern Iowa campus during daylight hours.
Two female students observed Kuester with his penis exposed and erect; he made no attempt to cover himself.
Kuester moved for appeal arguing (1) insufficient evidence that he "exposed" himself for purposes of the statute and (2) ineffective assistance of counsel for not requesting certain jury instructions.
The district court convicted and sentenced Kuester; the Court of Appeals reviewed sufficiency de novo and ineffective-assistance claims under Strickland.
The court considered whether exposure must be to a targeted viewer, whether intent can be to arouse oneself, and whether defense counsel erred in not requesting definitions/timing instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: whether Kuester "exposed" his genitals under the statute	State: evidence showed public exposure in a campus parking lot; jurors could find exposure and sexual intent	Kuester: exposure was private (inside vehicle) and not shown to be to the complaining witnesses	Held: Enough evidence of public exposure and sexual intent; exposure need not be to a targeted viewer; conviction affirmed
Ineffective assistance: failure to request (a) definition of "exposure" and (b) timing instruction linking sexual purpose to viewer's observation	State: instructions given were adequate; no breach or prejudice	Kuester: counsel breached duty by omitting clarifying instructions on "exposure" and concurrence in time of intent	Held: No breach—ordinary words need not be defined; substantial evidence showed concurrence of exposure and sexual purpose, so no prejudice; claim fails

State v. Jorgensen, 758 N.W.2d 830 (Iowa 2008) (indecent-exposure statute covers exhibitions "in such a place or under such circumstances that the exhibition is liable to be seen by others")
State v. Isaac, 756 N.W.2d 817 (Iowa 2008) (sexual purpose must exist at the time of exposure to the viewer)
State v. Robinson, 859 N.W.2d 464 (Iowa 2015) (standard for substantial-evidence review)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
State v. Kellogg, 542 N.W.2d 514 (Iowa 1996) (ordinary words need not be defined in jury instructions)
Weyerhaeuser Co. v. Thermogas Co., 620 N.W.2d 819 (Iowa 2000) (parties entitled to jury submission of legal theories supported by substantial evidence)