State of Iowa v. Thomas Aaron Ingram, 15-1984

Defendant Thomas Ingram was charged with multiple sexual-offense counts based on allegations by his then-12/13-year-old stepdaughter (M.H.) arising July 11 and August 29, 2014; the jury convicted on sexual abuse (third degree), lascivious acts with a child, and assault (lesser-included).
The State introduced M.H.’s contemporaneous diary entries (July 10–11, 2014) in which she described being raped by her stepfather, her fear, threats against her family, and self-harm; M.H. also testified at trial about the alleged incidents and the reasons for delayed disclosure.
Defense challenged admission of the diary and expert testimony but did not preserve all objections at trial; Ingram raises ineffective-assistance-of-counsel as an alternative ground for appellate review.
Expert witness Meghan Jones testified generally about typical behaviors of child sexual-abuse victims (delayed disclosure, denial, fear of not being believed, threats by abuser); defense argued this testimony impermissibly vouched for the victim.
The district court admitted the diary under the state-of-mind hearsay exception and permitted the expert’s general testimony; the court sentenced Ingram to concurrent/multiple prison terms and this appeal follows.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of victim’s diary	Diary admissible under hearsay exception for declarant’s then-existing state of mind/emotion; relevant to nonconsent and victim’s fear	Diary was hearsay and unduly prejudicial; counsel ineffective for not objecting	Court: Diary admissible under Rule 5.803(3); not unfairly prejudicial; counsel not ineffective; any error harmless because cumulative evidence
Expert testimony re: child abuse dynamics (vouching)	Expert may testify generally about typical symptoms/behavior to aid jury understanding; did not opine on truthfulness	Testimony indirectly vouched for victim’s credibility; counsel ineffective for not objecting	Court: Testimony stayed on permissible side of the thin line — general, not case-specific credibility opinion; no error and no ineffective assistance
Ineffective-assistance-of-counsel standard/application	N/A (prosecution)	Ingram: counsel failed essential duties by not objecting to diary and vouching testimony, causing prejudice	Court: Applied Strickland/Thorndike; presumes competence, found no deficient performance or prejudice — issues either admissible or cumulative; claim fails
Harmlessness of any evidentiary error	N/A	Any erroneous admission prejudiced verdict	Court: Even if error, admission was harmless given corroborating testimony and cumulative nature of diary/evidence

State v. Neiderbach, 837 N.W.2d 180 (Iowa 2013) (standard for reviewing evidentiary rulings)
State v. Dudley, 856 N.W.2d 668 (Iowa 2014) (limits on expert testimony that vouches for witness credibility)
State v. Brown, 856 N.W.2d 685 (Iowa 2014) (expert testimony and credibility boundaries)
State v. Jaquez, 856 N.W.2d 663 (Iowa 2014) (permitting general expert testimony about victim behaviors, rejecting credibility opinions)
Buenaventura v. State, 660 N.W.2d 38 (Iowa 2003) (hearsay-rule principles)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (state-of-mind hearsay exception analysis)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test)
State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (applying Strickland in Iowa context)