State of Iowa v. Robert Anthony Howard, 825 N.W.2d 32

Howard confessed after Detective Hull implied treatment for the child-abuse offense, creating an impermissible promise of leniency.
Medical testimony showed A.E. sustained anal penetration injuries within hours of evaluation, with external bleeding and a pattern unlikely from a hard stool.
Howard and Jessica were the sole caregivers with access to A.E. during the relevant period; other potential suspects were not present.
Howard was not Mirandized prior to interrogation, and the questioning included repeated references to getting help, treatment, and possible release.
District court denied suppression; trial admitted the confession; convictions for second-degree sexual abuse and child endangerment; Court of Appeals affirmed; Iowa Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the confession was admissible despite promises of leniency	State argues leniency promise not explicit; Madsen permits evidentiary test	Howard argues the promises of treatment created an impermissible inducement	Yes; interrogation crossed into impermissible leniency promise; confession inadmissible
Whether admission of the confession was harmless beyond a reasonable doubt	Confession is powerful but other evidence exists	Error not harmless given limited other direct evidence	Not harmless; new trial ordered on both counts

State v. Madsen, 813 N.W.2d 714 (Iowa 2012) (promises of leniency tested by evidentiary standard; promises before the plea-eliciting promise admissible)
State v. Mullin, 249 Iowa 10 (Iowa 1957) (per se exclusion of promises or inducements to confess)
State v. Polk, 812 N.W.2d 670 (Iowa 2012) (exclusionary rule deters police from eliciting false confessions)
State v. Whitsel, 339 N.W.2d 149 (Iowa 1983) (distinguishes promises of psychiatric help from leniency when mirandized)
State v. Moorehead, 699 N.W.2d 667 (Iowa 2005) (harms of tainted confession in OWI case; cited for nonharmlessness analysis)