State of Iowa v. Abel Gomez Medina

CourtSupreme Court of Iowa
DecidedMay 24, 2024
Docket22-0199
StatusPublished

This text of State of Iowa v. Abel Gomez Medina (State of Iowa v. Abel Gomez Medina) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Abel Gomez Medina, (iowa 2024).

Opinion

IN THE SUPREME COURT OF IOWA

No. 22–0199

Submitted February 21, 2024—Filed May 24, 2024

STATE OF IOWA,

Appellee,

vs.

ABEL GOMEZ MEDINA,

Appellant.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Polk County, Scott J. Beattie,

Judge.

The defendant appeals his criminal convictions after the district court per-

mitted a key witness to testify via closed-circuit television. DECISION OF COURT

OF APPEALS AND DISTRICT COURT JUDGMENT AFFIRMED.

McDermott, J., delivered the opinion of the court, in which all justices

joined. Alexander Smith (argued) and Benjamin D. Bergmann of Parrish

Kruidenier Dunn Gentry Brown Bergmann & Messamer L.L.P., Des Moines, for

Brenna Bird, Attorney General, and Bridget A. Chambers (argued) and

Sheryl Soich, Assistant Attorneys General, for appellee. 2

MCDERMOTT, Justice. Before Abel Gomez Medina’s trial for sexual abuse and indecent contact

with a child, the district court granted the State’s motion to permit his accuser—

a minor—to testify by closed-circuit television. When the trial eventually

occurred, his accuser testified over the course of two days. On the second day of

her testimony, she turned eighteen years old. Gomez Medina objected at trial,

arguing that permitting her to provide closed-circuit testimony the second day—

when she was a legal adult—violated Iowa’s statute authorizing closed-circuit

testimony. The district court overruled Gomez Medina’s objection, and the jury

ultimately convicted him. On appeal, Gomez Medina argues that permitting the

alleged victim’s closed-circuit testimony when she was eighteen violated Iowa’s

limited court testimony statute and the United States Constitution’s

Confrontation Clause.

I.

A.

Gomez Medina lived with his wife and four children (three were his step-

children and one was with his wife) in a single-family home. One morning before

school in 2019, Gomez Medina took away the phone of his fifteen-year-old step- daughter, Dorothy (a pseudonym), after learning that she’d been exchanging sex-

ually explicit messages with a boy. Gomez Medina then drove Dorothy to school.

Her day started with band class. After band, she went to the school counselor’s

office and reported to the counselor that Gomez Medina had been sexually abus-

ing her. She soon thereafter met with a forensic interviewer to whom she dis-

closed additional details, including that Gomez Medina had been sexually abus-

ing her since she was eleven years old.

In her testimony at trial, Dorothy provided graphic details of Gomez Medina’s sexual abuse, which Dorothy testified started when she was in fifth 3

grade. She testified that by the time she reported the sexual abuse to the school

counselor in ninth grade, the abuse was happening about five times a week.

According to Dorothy, the abuse would usually occur in the early morning hours

after her mother left for work. Because Gomez Medina feared she might become

pregnant, at some point he started buying her “morning after” contraceptive pills,

which he directed her to take as often as every other week.

Dorothy testified that before her disclosure to the school counselor, the

only other person she had told about the sexual abuse was a friend, and she

asked that friend to keep it a secret. Dorothy said she “didn’t want everyone

finding out” because she was “worried that everything would change in the

household” and her mother “wouldn’t believe [her].” She testified that when her

mother picked her up from school on the day she reported Gomez Medina’s

abuse to the counselor, her mother hardly spoke to her, wouldn’t look at her,

and didn’t try to comfort her or ask questions about what had happened.

Gomez Medina’s eleven-year-old son and Dorothy’s stepbrother, Frank

(also a pseudonym), stated in a forensic interview that after hiding under a bed,

he witnessed Gomez Medina and Dorothy doing inappropriate things. He said

he’d seen Gomez Medina and Dorothy “doing it,” saw the two of them naked together, and witnessed Dorothy “on top.” Frank reported that he told his mother

about it and that she got upset with Dorothy. But in Frank’s deposition testi-

mony later, he stated at times that he didn’t remember these things happening

in the bedroom. He repeatedly stated in his deposition that he didn’t want to talk

about it. Frank was ultimately determined unavailable to testify, and the district

court thus allowed the State to present both Frank’s forensic interview and dep-

osition testimony at trial.

A group of witnesses testified on Gomez Medina’s behalf that they never 4

saw anything inappropriate between Gomez Medina and Dorothy. These wit-

nesses included Dorothy’s mother; Gomez Medina’s father, who lived with the

family for a time; Dorothy’s maternal grandfather, who lived nearby; Dorothy’s

aunt; and Dorothy’s younger sister, with whom Dorothy shared a room.

B.

Before the trial, in May 2020, the State moved to permit closed-circuit tes-

timony by Dorothy and Frank under Iowa Code § 915.38 (2019), arguing that

“closed-circuit testimony is necessary to protect the minor witnesses [Dorothy]

and [Frank] from trauma caused by in-person testimony.” Gomez Medina re-

sisted. At a hearing on the motion, the court heard testimony from the guardian

ad litem for both Dorothy and Frank and from Dorothy’s therapist.

The guardian ad litem testified that requiring Dorothy and Frank to testify

in the presence of Gomez Medina would cause trauma and affect their ability to

testify truthfully. She opined that the stress each would suffer would be more

than the usual nervousness or excitement someone experiences when testifying

in court.

Dorothy’s therapist testified that Dorothy suffers from anxiety and

depression and that she experiences post-traumatic stress disorder because of the sexual abuse she endured. Her therapist reported that Dorothy had

expressed nervousness about seeing Gomez Medina in public places. And facing

Gomez Medina in a courtroom, according to Dorothy’s therapist, would create

emotional distress beyond the typical nervousness or excitement from testifying,

and Dorothy’s fear of providing testimony at trial had already caused enough

stress to require additional therapy sessions. Dorothy’s therapist opined that

closed-circuit testimony is necessary to protect Dorothy from further trauma.

She stated that Dorothy “wants to be able to speak her truth,” but that she fears Dorothy may be retraumatized with worsened conditions if the testimony “is not 5

done under a way that [Dorothy] can be able to discuss these concerns.” On

cross-examination, her therapist testified that Dorothy knew the difference

between telling the truth and lying, had stood up to her mother about the

allegations, and continued attending school regularly and maintaining high

grades even after reporting the abuse.

As the motion remained pending, the trial was delayed several times for

various reasons (including issues related to the COVID-19 pandemic). In August

2021, the district court granted the State’s motion for closed-circuit testimony

for Dorothy but denied it for Frank. The district court order noted that the State

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Rupe
534 N.W.2d 442 (Supreme Court of Iowa, 1995)
Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
State Public Defender v. Iowa District Court for Clarke County
745 N.W.2d 738 (Supreme Court of Iowa, 2008)
State Public Defender v. Iowa District Court
886 N.W.2d 595 (Supreme Court of Iowa, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Abel Gomez Medina, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-abel-gomez-medina-iowa-2024.