Background
Dustin Heckethorn was charged with sexually abusing his sixteen-year-old daughter, C.H., in 2022. C.H. testified that Heckethorn exposed himself to her, made sexual requests, and, in a camper, touched her buttocks and vagina and pulled down her pants and underwear. She later disclosed the incidents to her sister and mother, initially denied the allegations to police and a child-protective worker, then confirmed them after the worker read emails she had sent her mother.
Before trial, the district court excluded references to C.H.’s prior sexual-abuse allegations against Heckethorn from 2019 and early 2022 because the State had not provided the required notice for prior-bad-acts evidence. At trial, C.H. testified generally that she had been taught to tell the Department of Health and Human Services and police that everything was fine. Heckethorn sought a mistrial, asserting that the testimony violated the pretrial ruling. The district court denied the motion, and the jury convicted him of third-degree sexual abuse, incest, indecent exposure, and lascivious conduct with a minor.
The Court’s Holding
The Iowa Court of Appeals affirmed. It held that the district court did not abuse its discretion in denying a mistrial. C.H.’s brief, nonspecific reference to past contact with child-protective authorities and police did not mention the excluded prior sexual-abuse allegations or otherwise establish that Heckethorn had committed prior bad acts. The testimony was isolated and vague, other evidence established the family’s contact with the department, and Heckethorn declined the court’s offer of a cautionary instruction.
The court also found substantial evidence for every conviction. C.H.’s testimony alone could support the verdicts; Iowa law does not require corroboration of a victim’s testimony. Her account permitted a rational jury to find that the camper sexual contact was against her will, that Heckethorn knowingly exposed his genitals with sexual intent and in a manner offensive to C.H., and that he committed lascivious conduct by pulling down her pants and underwear with the requisite sexual intent.
Key Takeaways
- A vague reference to prior DHS or police contact does not necessarily violate an order excluding specific prior-bad-acts evidence.
- Declining an offered curative instruction can undermine a claimed mistrial prejudice argument.
- A sexual-assault victim’s uncorroborated testimony may constitute substantial evidence under Iowa law.
Why It Matters
The decision illustrates the high deference Iowa appellate courts give trial judges on mistrial motions, particularly where challenged testimony is limited and does not directly reveal excluded misconduct. It also confirms that credibility and corroboration arguments generally do not defeat a sufficiency challenge when the victim’s testimony, viewed favorably to the State, establishes the charged offenses.