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Case No. 20-1688

State of Iowa
Robert Stewart Eakin


State of Iowa


Robert Stewart Eakin

Attorney for the Appellee

Sharon K. Hall, Assistant Attorney General

Attorney for the Appellant

Maria Ruhtenberg, Assistant Appellate Defender

Court of Appeals

Court of Appeals Opinion

Opinion Number:
Date Published:
Aug 03, 2022

            Appeal from the Iowa District Court for Hardin County, John R. Flynn, Judge.  AFFIRMED IN PART, REVERSED IN PART, AND REMANDED.  Considered by Bower, C.J., and Vaitheswaran and Chicchelly, JJ.  Opinion by Vaitheswaran, J. (10 pages)

            Robert Eakin appeals his three convictions for third-degree sexual abuse, claiming the interviewing officer made improper promises of leniency and the district court gave an improper non-corroboration jury instruction.  OPINION HOLDS: The interviewing officer’s statements to Eakin prior to his confession were improper promises of leniency that made Eakin’s confession inadmissible.  The district court also erred in including the non-corroboration instruction.  The district court’s error regarding the instruction was harmless as to one of the convictions, as the victim’s testimony was corroborated by the victim’s mother.  The district court’s error was not harmless to the remaining two convictions, as Eakin’s confession was the only corroborating evidence.

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