State of Iowa v. James Kerkula Horace Jr.

CourtCourt of Appeals of Iowa
DecidedOctober 29, 2025
Docket24-0343
StatusPublished

This text of State of Iowa v. James Kerkula Horace Jr. (State of Iowa v. James Kerkula Horace Jr.) 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. James Kerkula Horace Jr., (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0343 Filed October 29, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

JAMES KERKULA HORACE JR., Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Melissa

Anderson-Seeber, Judge.

James Horace Jr. appeals his conviction for second-degree sexual abuse,

challenging the sufficiency of the evidence. AFFIRMED.

Austin Jungblut of Parrish Kruidenier, L.L.P., Des Moines, for appellant.

Brenna Bird, Attorney General, and Aaron Rogers, Assistant Attorney

General, for appellee.

Considered without oral argument by Ahlers, P.J., Buller, J., and

Potterfield, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2025). 2

POTTERFIELD, Senior Judge.

James Horace Jr. appeals his conviction for second-degree sexual abuse.

He challenges the sufficiency of the evidence, arguing that the State failed to show

venue and that the testimony of the victim was too conflicted to prove the alleged

abuse. We disagree. Horace waived any challenge to venue by declining to raise

it in a pretrial motion. As for the elements of Horace’s offense, we find substantial

evidence supports the district court’s verdict. We therefore affirm Horace’s

conviction.

I. Background

At the center of this case is a child—we will call her Sara1—who was born

in 2015. When Sara was two years old, she began making regular visits to

Horace’s home in Waterloo, Iowa. Horace’s wife looked after Sara while her

mother worked second shift at a processing plant. That was the routine for six

evenings a week until approximately October 2022, when Sara started to resist

going to Horace’s house. Sara’s mother found her behavior unusual, as Sara had

always enjoyed playing with Horace’s children. Eventually, Sara disclosed to her

mother that Horace had “put his hand down [her] pants” and touched her genitals.

Sara’s mother confronted Horace, and a criminal investigation ensued.

During a recorded interview in January 2023, Sara told a child protective worker

that something “wrong” had happened while she was at Horace’s house. When

asked what she meant, Sara explained that somebody had used their hand to

touch her genitals under her clothes. Horace was also interviewed by police. He

1 To protect the child’s identity, we adopt the randomly generated pseudonym used

by the State in its appellate brief. 3

initially alleged that he was unable to recall some of his interactions with Sara

because he often drank alcohol in the evenings. But he eventually told a detective

that he may have put his hand down Sara’s pants. As Horace put it, “if she says

so, it did happen.”

The State charged Horace with one count of sexual abuse in the second

degree. At a bench trial in October 2023, Sara—then seven years old—initially

denied any recollection of Horace or his house. With further questioning, she

divulged that she recognized Horace from “before when I had a babysitter,” and

that Horace “would always follow me and put his hands in my pants.” Sara testified

that Horace touched her “front” or “coochie,” although she equivocated when

asked whether he touched her inside or outside her underwear. She also gave

conflicting answers as to the frequency of the abuse. At one point, Sara testified

that Horace touched her “every time” she went to his house. Later, she said it was

“about eleven times.”

Horace took the stand at trial, denying any sexual contact with Sara and

renouncing the earlier statements he made to police. In a carefully reasoned

ruling, the district court rejected Horace’s version of the facts and found him guilty

as charged. Horace now appeals, challenging the sufficiency of the evidence. He

argues the record fails to support the district court’s finding that the abuse took

place—if at all—in Black Hawk County. He also challenges the court’s decision to

credit Sara’s version of events, contending her testimony was too conflicted to

prove the alleged abuse. 4

II. Standard of Review

We review challenges to the sufficiency of the evidence for correction of

errors at law. State v. Mathis, 971 N.W.2d 514, 516 (Iowa 2022). We must affirm

the conviction if it is supported by substantial evidence, which is evidence

“sufficient to convince a rational trier of fact the defendant is guilty beyond a

reasonable doubt.” Id. at 516–17 (citation omitted). The substantial evidence

standards we use when reviewing jury verdicts apply equally in cases tried to the

court. State v. Ledezma, 549 N.W.2d 307, 310 (Iowa Ct. App. 1996).

III. Discussion

a. Location of the Offense

Horace asserts that the State failed to prove any of the alleged sexual abuse

occurred in Black Hawk County, which is the venue where he was tried. Horace

concedes the record shows that he moved to Waterloo in 2017 and that any abuse

would have occurred inside his home, but he contends “it was never established

the residence was located in Black Hawk County.” The State argues that Horace

waived any venue challenge by failing to raise it in a pretrial motion.

Generally speaking, a criminal action must “be tried in the county in which

the crime is committed.” Iowa Code § 803.2(1) (2022). This requirement stems

from the common law notion that “the situs of the alleged crime is usually the home

of the defendant” and the place where “witnesses are accessible for the purpose

of trial.” State v. Dorsey, 16 N.W.3d 32, 42 (Iowa 2025) (citation omitted). Of

course, those interests sometimes must yield to due process rights. See id. Our

procedural rules permit either party to seek a change of venue when necessary to

ensure a fair trial. See Iowa R. Crim. P. 2.11(4)(f), (11). However, a venue 5

objection must be raised prior to trial; otherwise, it is waived. Iowa Code

§ 803.2(3). Horace never moved for a change of venue. We therefore agree with

the State that any objection to the place of his trial is waived on appeal. Id.

“Venue is not an essential element” of a charged offense. State v. Allen,

293 N.W.2d 16, 20 (Iowa 1980). But even if it were, there is substantial evidence

supporting the district court’s finding that the crime occurred in Black Hawk County.

Horace testified that he relocated to Iowa in 2016 and later moved to a home on

Western Avenue in Waterloo. He conceded that Sara visited his house, which is

where Sara testified that Horace abused her. Nothing in the record suggests that

Horace ever encountered Sara outside of his Waterloo home. The district court—

as finder of fact—was entitled to rely on its common geographical knowledge when

deciding whether venue was correct. See State v. Stevens, 719 N.W.2d 547, 552

(Iowa 2006) (explaining jurors may “rely on their common knowledge to support a

conviction”).

Horace waived any objection to venue, and he does not appear to dispute

that the charged conduct took place in Waterloo.

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

Related

State v. Stevens
719 N.W.2d 547 (Supreme Court of Iowa, 2006)
State v. Smith
508 N.W.2d 101 (Court of Appeals of Iowa, 1993)
State v. Hildreth
582 N.W.2d 167 (Supreme Court of Iowa, 1998)
State v. Ledezma
549 N.W.2d 307 (Court of Appeals of Iowa, 1996)
State v. Constable
505 N.W.2d 473 (Supreme Court of Iowa, 1993)
State v. Pearson
514 N.W.2d 452 (Supreme Court of Iowa, 1994)
State v. Allen
293 N.W.2d 16 (Supreme Court of Iowa, 1980)
State of Iowa v. Randy Scott Meyers
799 N.W.2d 132 (Supreme Court of Iowa, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. James Kerkula Horace Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-james-kerkula-horace-jr-iowactapp-2025.