State of Iowa v. Matthew L. Wilson, 16-0555

Victim (M.W.), age eight at the time, reported that her father, Matthew Wilson, stopped his van, exposed his penis, had her touch it, and ejaculated; she later disclosed the incident to a DHS worker.
DHS worker Amanda Seymour referred the matter to Deputy Chad Ellis; Ellis interviewed Wilson at his father’s home with the father asked to leave the room.
During the interview Ellis (in plain clothes but wearing a badge and firearm) expressed empathy, referenced counseling/treatment and "help" and "closure" repeatedly, and falsely suggested a witness could identify Wilson.
After a period of questioning in which Ellis narrated events and expressed sympathetic reassurances, Wilson admitted sexual contact and ejaculation; Ellis then read Miranda rights and arrested him.
Wilson moved to suppress the confession as induced by promises of leniency; the district court denied the motion and a jury convicted Wilson of second-degree sexual abuse; Wilson appealed the suppression ruling.

Issue	State's Argument	Wilson's Argument	Held
Whether Ellis’s interview included promises of leniency rendering the confession inadmissible	Interview statements were expressions of empathy and references to help/family counseling, not promises of leniency or specific benefits	Ellis’s sympathetic language and references to "help," "therapy," and "closure" implied leniency and induced the confession	Denied: court found language did not amount to an explicit or implicit promise of leniency under the evidentiary test

State v. Breuer, 577 N.W.2d 41 (Iowa 1998) (preservation of error on suppression rulings)
State v. Polk, 812 N.W.2d 670 (Iowa 2012) (applying common-law evidentiary test when words used are undisputed)
State v. Howard, 825 N.W.2d 32 (Iowa 2012) (confession excluded where officer created false impression that treatment would substitute for punishment)
State v. Madsen, 813 N.W.2d 714 (Iowa 2012) (explaining per se evidentiary exclusion: any inducement or promise bars admissibility)
State v. Wilson, 247 N.W.2d 736 (Iowa 1976) (trial court must hold an evidentiary hearing and decide admissibility of disputed confessions)