State of Iowa v. Aidan Christopher Ralph

CourtCourt of Appeals of Iowa
DecidedMarch 5, 2025
Docket23-2036
StatusPublished

This text of State of Iowa v. Aidan Christopher Ralph (State of Iowa v. Aidan Christopher Ralph) is published on Counsel Stack Legal Research, covering Court of Appeals 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. Aidan Christopher Ralph, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-2036 Filed March 5, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

AIDAN CHRISTOPHER RALPH, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Story County, Bethany Currie (trial)

and John J. Haney (sentencing), Judges.

A defendant appeals his conviction for third-degree sexual abuse.

AFFIRMED.

Gary Dickey of Dickey, Campbell, & Sahag Law Firm, PLC, Des Moines, for

appellant.

Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney

General, for appellee.

Heard by Tabor, C.J., and Schumacher and Chicchelly, JJ. 2

TABOR, Chief Judge.

A jury convicted Aidan Ralph of third-degree sexual abuse and assault

causing bodily injury for pushing his girlfriend, A.C., into a staircase—fracturing a

vertebra in her spine—then sexually assaulting her in his bedroom. In appealing

his sexual-abuse conviction, Ralph raises two evidentiary issues. First, he claims

the district court abused its discretion by allowing a police officer to testify that

other witnesses’ statements aligned with A.C.’s accusations. Second, he claims

the court abused its discretion in admitting evidence that he physically abused A.C.

on prior occasions to establish his motive for sexually abusing her. He requests

that we reverse his sexual-abuse conviction and remand for a new trial. Finding

the court properly exercised its discretion in admitting the challenged evidence, we

affirm.

I. Facts and Prior Proceedings

Ralph and A.C. started dating in high school. After graduation, they both

attended Iowa State University, where they continued their romantic relationship.

On a December evening in 2022, they made plans to celebrate Ralph’s birthday.

They started by drinking at a “pregame” party. Afterward, A.C. returned to her

dorm with her roommates, and Ralph went out to a bar. A.C. planned to “meet up

with him there.” But instead, Ralph came to A.C.’s dorm, upset that he had lost

his ID cards. A.C. recalled that Ralph “started getting loud.” A.C. told Ralph to

leave. So he went back to his apartment. Meanwhile, A.C. and her roommates

went out to a bar without him.

But soon Ralph sent A.C. a barrage of text messages begging her to leave

her friends and come to his place. Acceding to his wishes, A.C. left the bar and 3

took an Uber to Ralph’s apartment. When she arrived, she went upstairs to Ralph’s

bedroom.1 Ralph was lying in his bed crying. He told A.C. that she embarrassed

him by going out without him. A.C. recalled that when she didn’t respond, “he

started getting really aggressive”—rising from his bed and yelling at her to leave.

Frightened, A.C. left the bedroom, grabbed her shoes, and ran downstairs to the

entryway. Ralph caught up to her there. He was “still continuously telling [her] to

leave” and started “shoving [her] around.” To stop her from leaving, Ralph took

A.C.’s shoes and “threw them across the street.” Then, as A.C. described it: “he

had pushed me really hard against the stairs where I hit my head really, really hard

and my back.” The impact fractured a vertebra in her spine.

A.C. “didn’t try leaving after that” because she was in “a lot of pain.” She

asked Ralph to help her, but he “didn’t care at all.” According to A.C., after he

pushed her into the stairs, Ralph “just continued yelling” at her and told her she

“deserved it.” A.C. then climbed the stairs to Ralph’s bedroom, “crying the whole

time.” Ralph followed her, telling her to “be quiet” because “his roommate was

there.” Once they were inside Ralph’s bedroom, A.C. took off the tight pants she’d

been wearing because they were “really painful” and got into Ralph’s bed. She

testified that she “wanted to make it seem like [she] was going to stay” so Ralph

wouldn’t be angry. Ralph continued yelling at her. A.C. asked him to call an

ambulance for her. He refused.

1 Ralph lived in a three-story apartment. The ground level was the entryway, the second floor was the living room and kitchen area, and the third floor was a hallway and two bedrooms. 4

According to A.C., Ralph “got quiet” after a while. Then, without saying

anything, he climbed onto the bed and “trie[d] having sex with [her].” A.C. told him

“no.” But Ralph didn’t stop. He pulled her underwear to the side and started having

vaginal intercourse with her. While Ralph was doing this, A.C. “said ‘no’ a few

times.” And she was “crying the whole time.” She didn’t physically resist him

because she “didn’t want to get more hurt.” Eventually, Ralph “flipped [her] over,”

then became “frustrated.” Then he stopped having intercourse with her and asked

her to “give him a blow job.” A.C. again said “no.” After that, Ralph “went right

back into just yelling” at her. Sometime later, A.C. fell asleep. A.C. testified that

she didn’t want to have sex with Ralph that night “at all.”

The next morning, Ralph called one of A.C.’s roommates to get her. He told

the roommate that A.C. “had a bad accident where [she] fell down the stairs getting

a glass of water” and that “she was really hurt.” A.C. told Ralph that she “was

going to go along” with that story because she “didn’t want to make him angry

anymore.” Two of A.C.’s roommates picked her up. One of them recalled that

when Ralph “brought [A.C.] out” of the apartment, “she was walking but very

poorly”; “she looked, like, miserable, disheveled, and [when] she got in the back

seat of my car, . . . she didn’t say a single word to us.” Ralph rode with A.C. and

her roommates back to their dorm. When they arrived, Ralph went with A.C.

“straight to her room.” About two weeks later, A.C. and Ralph broke up.

When she returned home to Illinois for winter break, A.C. told her mother

that Ralph physically and sexually assaulted her. A.C.’s uncle reported the

incident to the Ames Police Department. Officer Adam McPherson investigated.

McPherson interviewed A.C. over the phone. He also interviewed A.C.’s 5

roommates; Ralph’s roommate and his girlfriend, who were in the apartment on

the night of the incident; and Ralph. At first, Ralph told Officer McPherson that

A.C. “just showed up” at his apartment “uninvited,” and “he told her to leave.” He

first denied that he pushed A.C. or “that there was any sexual activity.” When

McPherson continued pressing him about what happened, Ralph admitted pushing

A.C. He also “admitted that they engaged in consensual sexual intercourse.”

The State charged Ralph with sexual abuse in the third degree, a class “C”

felony, in violation of Iowa Code sections 709.1 and 709.4(1) (2022), and domestic

abuse assault causing bodily injury, a serious misdemeanor, in violation of

sections 708.1, 708.2A(1), and 708.2A(2)(b). The case went to jury trial five

months later.

The State filed a pretrial motion to introduce evidence that Ralph physically

assaulted A.C. on prior occasions. The district court reserved ruling on the

admissibility of those incidents until trial. The court cautioned: “[T]he State should

presume that none of its prior bad acts evidence will be admitted unless and until

the State can demonstrate during trial that it relates to a legitimate, disputed issue

other than character or propensity.” The court further instructed in its pretrial ruling:

“If Mr.

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