State of Iowa v. Randy Scott Meyers, 2011 Iowa Sup. LEXIS 42

Meyers began a relationship with Mindy, Patricia's daughter, who was six when they met; Meyers moved in with Patricia and the two children in 1994.
In 1995 Meyers was convicted of lascivious acts with a child after Mindy’s injury; he served a five-year sentence and later lived with Mindy again.
Patricia suffered from bipolar disorder and the household saw controlling and abusive behavior by Meyers toward Mindy and her brother.
DHS investigated Mindy’s injuries in 2004 and Mindy began crack cocaine treatment thereafter, with Meyers providing drugs and exerting control.
Mindy lived with Meyers in his trailer from late 2004 to January 2005; there were contemporaneous observations of romantic contacts and a lettered relationship describing sexual activity.
Meyers was later convicted of lascivious conduct with a minor (the Mindy-related offense) and of distributing a controlled substance to a minor; he received separate sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports two sex acts occurred.	Meyers admitted acts in jail letters; corroboration needed.	Admissions alone insufficient without corroboration.	Yes; sufficient corroboration supported two sex acts.
Whether the sex acts were by force or against Mindy’s will, including psychological coercion.	Nonconsent can be established by psychological factors in context.	Consent negated only by physical force or explicit lack of consent, not psychological state.	Psychological circumstances may negate consent; sufficient evidence supported nonconsent here.
Whether there was sufficient evidence of lascivious conduct with a minor.	Age, relationship of authority, and evidence of coercion show disrobing for sexual purposes.	Insufficient linkage between coercion and disrobing.	Sufficient evidence of coerced disrobing established.
Whether Meyers’ pro se due process claim was preserved and may be addressed.	N/A	Argues due process violation due to dismissal issues.	Waived; not addressed.

State v. Hennings, 791 N.W.2d 828 (Iowa 2010) (sufficiency standard for evidence; substantial evidence standard)
State v. McCullah, 787 N.W.2d 90 (Iowa 2010) (evidence adequacy; rational finder standard)
State v. Bauer, 324 N.W.2d 320 (Iowa 1982) (consideration of victim's mental state in nonconsent)
State v. Bolsinger, 709 N.W.2d 560 (Iowa 2006) (fraud in fact can vitiate consent; broad interpretation of consent)
Kraklio, 560 N.W.2d 16 (Iowa 1997) (review of evidence in light for upholding verdict)
State v. Welton, 300 N.W.2d 157 (Iowa 1981) (interpretation of statutory language and intent)
State v. Capper, 539 N.W.2d 361 (Iowa 1995) (separate-count sufficiency analysis; count-by-count approach)