State of Iowa v. Brent Richard Fischer

CourtCourt of Appeals of Iowa
DecidedDecember 20, 2023
Docket22-1058
StatusPublished

This text of State of Iowa v. Brent Richard Fischer (State of Iowa v. Brent Richard Fischer) 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. Brent Richard Fischer, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-1058 Filed December 20, 2023

STATE OF IOWA, Plaintiff-Appellee,

vs.

BRENT RICHARD FISCHER, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Boone County, John J. Haney,

Judge.

Brent Fischer challenges his convictions for second-degree sexual abuse.

AFFIRMED.

Cathleen J. Siebrecht of Siebrecht Law Firm, Pleasant Hill, for appellant.

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

General, for appellee.

Considered by Greer, P.J., and Schumacher and Ahlers, JJ. 2

AHLERS, Judge.

A jury found Brent Fischer guilty of six counts of second-degree sexual

abuse for abusing a child. On appeal, Fischer challenges the admissibility of

certain evidence. He also argues his convictions are not supported by sufficient

evidence.

I. Sufficiency of the Evidence

We first address Fischer’s challenge to the sufficiency of the evidence

supporting his convictions. On this issue, we review for correction of errors at law.

See State v. Crawford, 972 N.W.2d 189, 202 (Iowa 2022). Jury verdicts bind us if

they are supported by substantial evidence. Id. Evidence is substantial if it is

sufficient to convince a rational factfinder that the defendant is guilty beyond a

reasonable doubt. Id. In assessing whether evidence is substantial, “we view the

evidence in the light most favorable to the State, including all ‘legitimate inferences

and presumptions that may fairly and reasonably be deduced from the record

evidence.’” Id. (quoting State v. Tipton, 897 N.W.2d 653, 692 (Iowa 2017)).

When, as here, the defendant does not object to the jury instructions, those

instructions become the law of the case for purposes of sufficiency-of-the-evidence

challenges. See State v. Mathis, 971 N.W.2d 514, 518 (Iowa 2022). The

marshaling instructions for each count required the State to establish two

elements: (1) “Fisher performed a sex act with [the child], as explained in [another

instruction]” and (2) “Fisher performed the sex act while [the child] was under the

age of 12 years.”1 Another instruction explained,

1 Each marshaling instruction for the six counts covered sex acts occurring at

different points in time. As to count I, the marshaling instruction covered acts 3

“sex act” means any sexual contact: 1. By penetration of the penis into the vagina or anus. 2. Between the mouth of one person and the genitals of another. 3. Between the genitals of one person and the genitals or anus of another. 4. Between the finger or hand of one person and the genitals or anus of another person. 5. By use of artificial sex organs or substitutes therefor in contact with the genitalia or anus. You may consider the type of contact and the circumstances surrounding it in deciding whether the contact was sexual in nature.

The jury instructions also explained, “The parties have stipulated that [the child]

was under the age of 12 years old during the time frames set forth” in the

marshaling instructions. So, the only fighting issue is whether Fischer performed

six sex acts on the child.

The child testified at trial that Fischer would touch and lick her “vagina and

[her] breasts and [her] butt.” She explained Fischer first abused her when she was

in either kindergarten or first grade and last abused her when she was in fifth grade.

She estimated the abuse occurred about every other month and at least every

year. This testimony is sufficient to establish Fischer committed at least six sex

acts on the child. Yet Fischer attacks the child’s testimony as not credible. He

occurring between March 1, 2008, and June 30, 2009. As to count II, the marshaling instruction covered acts occurring between July 1, 2009, and June 30, 2010. As to count III, the marshaling instruction covered acts occurring between July 1, 2010, and June 30, 2011. As to count IV, the marshaling instruction covered acts occurring between July 1, 2011, and June 30, 2012. As to count V, the marshaling instruction covered acts occurring between July 1, 2012, and June 30, 2013. As to count VI, the marshaling instruction covered acts occurring between July 1, 2013, and September 30, 2014. A separate instruction explained, “The State does not have to prove the specific date on which the crime occurred. The date of the offense is not a material element of any of the charges and is provided only as a frame for reference.” 4

contends the child’s testimony was too vague and contradictory and that it lacked

corroboration.

While we agree with Fischer that his convictions hinge on the child’s

testimony, we disagree with his challenges to her testimony. First, we reiterate

that a complaining witness’s testimony does not require corroboration. State v.

Kraii, 969 N.W.2d 487, 491 (Iowa 2022) (confirming that corroboration of testimony

of an alleged victim is not required in sexual abuse cases).

Second, in assessing the sufficiency of the evidence, it is not the appellate

court’s role to “resolve conflicts in the evidence, to pass upon the credibility of

witnesses, to determine the plausibility of explanations, or to weigh the evidence;

[as] such matters are for the jury.” State v. Musser, 721 N.W.2d 758, 761 (Iowa

2006) (quoting State v. Williams, 695 N.W.2d 23, 28 (Iowa 2005)).

Third, the child provided details about several instances of abuse,

undermining Fischer’s complaints that the testimony was somehow too vague. For

example, she recalled one time when Fischer came into her room to collect a tooth

she lost from under her pillow, abused her, and then left money under her pillow.

She testified about another specific instance that occurred the night before her

birthday—she recalled the sound her air conditioner made, the sound of Fischer

walking up the stairs toward her bedroom, wedging herself between her bed and

the wall, trying to hide from Fischer under a blanket, and then Fischer touching

and licking her genitals, breasts, and anus. And it does not neutralize the

sufficiency of the evidence that the child could not recall the specific details of every

instance of abuse, which occurred over a number of years and several years prior 5

to her testimony.2 See State v. Parker, No. 22-0491, 2023 WL 7391664, at *2 (Iowa

Ct. App. Nov. 8, 2023) (“We also note that she was sixteen at the time of trial,

describing events that occurred when she was eight, nine, and ten years old. We

do not require total precision from the victim’s testimony.”).

In short, there is sufficient evidence supporting Fischer’s convictions for

second-degree sexual abuse.

II. Evidentiary Challenges

We move on to Fischer’s evidentiary challenges. He argues the court

should not have admitted photos of the child in first, second, and third grade. He

also contends the district court permitted impermissible vouching and mirroring

testimony from an expert witness.

We review evidentiary challenges for an abuse of discretion, our most

deferential standard. State v. Webster, 865 N.W.2d 223, 231 (Iowa 2015). “An

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

Related

State v. Biddle
652 N.W.2d 191 (Supreme Court of Iowa, 2002)
State v. Williams
695 N.W.2d 23 (Supreme Court of Iowa, 2005)
State v. Musser
721 N.W.2d 758 (Supreme Court of Iowa, 2006)
State v. Rodriquez
636 N.W.2d 234 (Supreme Court of Iowa, 2001)
State of Iowa v. Patrick Michael Dudley
856 N.W.2d 668 (Supreme Court of Iowa, 2014)
State of Iowa v. Tyler James Webster
865 N.W.2d 223 (Supreme Court of Iowa, 2015)
State of Iowa v. Eddie Tipton
897 N.W.2d 653 (Supreme Court of Iowa, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Brent Richard Fischer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-brent-richard-fischer-iowactapp-2023.