State of Iowa v. Soji Itunu Olutunde, 2016 Iowa Sup. LEXIS 51

Defendant Soji Olutunde, a caregiver, was criminally charged with dependent adult abuse after an alleged punch to a disabled resident; two coworkers reported observing the incident, defendant disputed the assault.
During pretrial discovery the State learned of a prior founded dependent-adult-abuse report against Olutunde that had been sealed under Iowa Code § 235B.9 because more than ten years had elapsed.
The State moved to unseal the prior founded report and to allow its use to impeach the defendant or his character witnesses if they denied prior abuse on the stand or in applications.
The district court granted the State’s motion, ordering the Department to unseal the founded report and ruling the report’s existence and contents could be used for impeachment if the defense “opened the door.”
The Iowa Supreme Court granted discretionary review and stayed proceedings; the core legal question was whether a court may order unsealing of a founded dependent-adult-abuse report that has been sealed under § 235B.9(1).
The Court reversed: holding the statute mandates automatic sealing after ten years and does not authorize post-sealing unsealing by court order; the Court declined to decide whether sealed-report contents could ever be used for impeachment.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Olutunde)	Held
Whether a district court may unseal a founded dependent-adult-abuse report that has been sealed under Iowa Code § 235B.9(1)	§ 235B.9 does not prohibit a court from ordering a sealed founded report unsealed; prosecutors need access for impeachment and to determine admissibility.	§ 235B.9 mandates sealing of founded reports after ten years and contains no provision allowing courts to unseal such records; sealed records must remain sealed.	Reversed: court may not unseal a founded report sealed under § 235B.9(1); sealing is automatic and mandatory after ten years absent statutory exceptions.
Whether the State may use contents of a sealed founded report to impeach defendant or character witnesses	Even if sealed, contents may be used to impeach if a witness falsely claims no prior abuse.	Use would undermine statutory privacy protections and the statutory sealing regime.	Not decided: Court declined to reach the evidentiary impeachment question on this record.

State v. Neiderbach, 837 N.W.2d 180 (Iowa 2013) (standard of review for evidentiary rulings and impeachment principles)
Nichols v. United States, 136 S. Ct. 1113 (2016) (court will apply plain statutory text and decline to add exceptions not found in statute)
In re Estate of Whalen, 827 N.W.2d 184 (Iowa 2013) (may not extend or change statute under guise of construction)
State v. Parker, 747 N.W.2d 196 (Iowa 2008) (impeachment governed by rules of evidence; prior statements or charges may be used in limited impeachment contexts)
State v. Walden, 870 N.W.2d 842 (Iowa 2015) (legislative intent may be inferred from statutory omissions)
Oyens Feed & Supply, Inc. v. Primebank, 808 N.W.2d 186 (Iowa 2011) (interpretive principle that selective statutory phrasing indicates legislative intent)