State v. Anderson

Mark Anderson (defendant) lived with his wife on his family farm in Iowa. In the summer of 1998, Anderson hired J.D., a 15-year-old girl, to work on the farm. During the summer, Anderson engaged in sexual intercourse with J.D. on four separate occasions. J.D.’s parents became suspicious of Anderson and forced J.D. to quit her job on Anderson’s farm. J.D. did not tell her parents that she had sexual intercourse with Anderson. In September 1999, the principal at J.D.’s school, where Anderson worked as a softball coach, told J.D.’s parents that he had received a report that Anderson had sexually abused J.D. Following that report, J.D. admitted to her parents and to the police that Anderson had engaged in sexual intercourse with her. Anderson was charged with statutory rape. During the trial, J.D. described the four instances of sexual abuse, described the interior of the camper in which the assaults took place, and described the appearance of Anderson’s naked body. The prosecution called Anderson’s wife, who was by then his ex-wife, to testify, and she corroborated J.D.’s descriptions of the camper and Anderson’s body. Anderson’s ex-wife also shared details from a conversation she had with Anderson in the summer of 1998 about his concerning relationship with J.D. Anderson was convicted and sentenced to prison. Anderson appealed, arguing that the trial court erred by allowing his ex-wife to testify in contravention of spousal privilege.