State v. Baker

Supreme Court of Iowa · 2004 · Evidence

679 N.W.2d 7 (Iowa 2004)

Updated August 22, 2026

Evidencerape-shield ruleIowa Rule of Evidence 5.412Rule 5.403impeachmentcross-examinationprior false accusationssexual abuse

Facts

At trial, the State presented evidence that Julia, who was thirteen, left a pool with the twenty-four-year-old defendant, drank alcohol he purchased, and later had sexual intercourse with him after he pulled over on the way back to a convenience store. Julia also told her friends that on an earlier occasion she had sexual relations with a neighbor, but she later denied that incident. Before trial, the defendant sought to introduce evidence that the neighbor story was false in order to impeach Julia's credibility. The district court found the prior claim was false but excluded the evidence as unfairly prejudicial and contrary to the spirit of the rape-shield law.

Issue

Does Iowa's rape-shield rule bar cross-examination of a complaining witness about a prior false claim of sexual activity, and if not, did the district court abuse its discretion by excluding that evidence under rule 5.403 as unfairly prejudicial?

Rule

A prior false claim of sexual activity is not 'past sexual behavior' within Iowa's rape-shield rule, because a false allegation is not sexual behavior. Such evidence is therefore evaluated under ordinary relevance principles and rule 5.403, and embarrassment or reputational harm to a witness from exposure of a false claim is not the kind of unfair prejudice that outweighs clearly relevant impeachment evidence, especially when a criminal defendant's right to present a defense is at stake.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a sexual assault prosecution in Des Moines, Maya Lopez claims that Noah Mercer assaulted her after a party. Noah has proof that, six months earlier, Maya told classmates she had slept with a coworker in Cedar Rapids, but the trial judge finds after a pretrial hearing that the story was fabricated.

How should the court classify Noah's proposed impeachment evidence?

Explanation. The majority held that a prior false claim of sexual activity is not 'past sexual behavior' within the rape-shield rule. Because a fabricated claim is not sexual behavior, it falls outside both the letter and spirit of the rape-shield law. The evidence must therefore be analyzed under ordinary relevance principles and Rule 5.403, not categorically excluded.