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State of Iowa v. Patrick Edouard
Citations: 854 N.W.2d 421; 2014 WL 3537034; 2014 Iowa Sup. LEXIS 85Docket: 12–1899
Court: Supreme Court of Iowa; July 18, 2014; Iowa; State Supreme Court
Original Court Document: View Document
In the case of State of Iowa vs. Patrick Edouard, the Iowa Supreme Court reviewed an appeal from a district court's convictions against a pastor for sexual exploitation under Iowa Code section 709.15. The pastor was convicted on four counts of sexual exploitation and one count of a pattern of such exploitation involving four women from his congregation. On appeal, Edouard raised several claims, including improper jury instructions, exclusion of expert testimony, insufficiency of evidence, denial of discovery for a victim's counseling records, constitutionality of the statute as applied to him, exclusion of certain evidence, and errors related to the restitution amount. The Iowa Court of Appeals reversed the convictions, citing improper jury instructions and exclusion of expert testimony as errors. However, the Supreme Court disagreed with the appellate court's findings on these issues, vacated its decision, and upheld the convictions in part. The Supreme Court did find merit in two of the pastor's claims: it required an in camera review of the victim's counseling records and reversed the restitution award, remanding for further proceedings on both points. The Supreme Court affirmed the convictions and sentence in all other respects, establishing that the jury's verdicts were supported by evidence and proper legal standards. V.B. visited Edouard's house, where he and V.B. went to his locked study, ostensibly to avoid interruptions. During their conversation, V.B. expressed her struggles with adoption and her marriage, leading Edouard to make sexual advances toward her. Following this encounter, Edouard frequently contacted V.B., suggesting her marital issues stemmed from unmet needs, implying a romantic interest in her. Their relationship involved regular phone conversations and secret meetings at hotels, during which Edouard insisted V.B. did not genuinely want to adopt and that her difficulties were due to her marriage. Edouard also solicited financial support from V.B., receiving $70,000 under the guise of needing assistance. The relationship waned after V.B. adopted a child, and in October 2009, she confronted Edouard about his manipulative behavior, leading him to panic when she cut off communication. S.K., another church member, received unwanted attention from Edouard after her husband's departure. Struggling with family issues and her husband's infidelity, S.K. initially found Edouard's calls comforting. However, after Edouard made an inappropriate comment, she later reached out to him in a vulnerable state. During a subsequent meeting, S.K. disclosed her marital problems, which led to Edouard asking to kiss her, resulting in a sexual relationship that developed over time. In spring 2008, Edouard took S.K. to his basement study, locked the door, and initiated sexual relations, warning her to keep it a secret under threats of reputational harm and family destruction. Their sexual encounters occurred six to eight times, during which S.K. felt Edouard exerted significant power over her. After he ended the relationship, he offered ongoing support. W.B., also a member of the Covenant Reformed Church, experienced flirtation from Edouard during a church service in August 2007, leading to distress and a meeting she arranged to end the flirtation. During their meeting in Edouard’s basement office, he locked the door and engaged in personal discussions, eventually leading to sexual contact, which he insisted she keep secret from her husband. Their sexual relationship continued for years, with Edouard advising her on marital counseling sessions. A.B., another church member, was struggling with personal issues when Edouard contacted her to check on her well-being. During a meeting in his basement, he locked the door and made her uncomfortable with personal questions about her family and sexual history, expressing a desire to get to know her better. Their conversations continued, with Edouard frequently probing about her past, including any childhood sexual abuse. A.B. described her relationship with Edouard as increasingly intimate, noting that he became aware of her vulnerabilities. Their relationship began with kisses and frequent calls, eventually leading to sexual relations starting in May 2008, which continued weekly for over two years. Edouard insisted that their relationship be kept a secret. In May 2010, Edouard disclosed past sexual relationships with A.B.’s sister-in-law, V.B., which devastated A.B. Despite this revelation, they continued their sexual involvement. In December 2010, A.B.’s husband discovered Edouard at their home during an intimate encounter, leading him to alert church elders. Edouard subsequently resigned and attempted to manage the fallout by contacting W.B. and instructing her to deny their affair. He faced multiple charges, including sexual abuse and sexual exploitation by a counselor or therapist, and after a trial that began in August 2012, the jury found him not guilty of sexual abuse but guilty of five counts of sexual exploitation. He received a total sentence of six years, with varying terms for the different counts. Edouard appealed, raising several issues, including the sufficiency of evidence regarding mental health services, discovery denials, and claims of constitutional violations related to the sexual exploitation statute. The case was transferred to the court of appeals, which found errors in jury instruction and the exclusion of expert testimony, ultimately reversing the decision and remanding for a new trial. The State then sought further review, which was granted. Challenges to jury instructions are reviewed for legal error, while claims regarding the denial of requested instructions are assessed for abuse of discretion. Constitutional issues related to discovery rulings are evaluated de novo, as are challenges to a statute's constitutionality, with statutes presumed constitutional. The admissibility of evidence is reviewed for abuse of discretion, and sufficiency of evidence challenges are also corrected for legal errors. Restitution orders are similarly reviewed for legal errors. The analysis begins with the appeal of Edouard focusing on instructional and evidentiary issues that prompted a reversal and remand by the court of appeals. Under Iowa law, sexual exploitation by a counselor or therapist occurs when there is sexual conduct with a patient, client, or former client within one year after mental health services have concluded, with the intent to satisfy sexual desires. This is classified as a serious misdemeanor, and a pattern of such conduct is a class 'D' felony. The statute broadly defines 'counselor or therapist' to include various professionals and non-professionals providing mental health services, which encompass treatment or counseling for cognitive, emotional, or social dysfunctions. Previous cases have upheld the statute against vagueness and overbreadth challenges, affirming convictions of individuals, such as a hypnotherapist, who engaged in sexual conduct with clients during mental health treatment. The statute in question does not encompass informal personal relationships, such as marriage, as "mental health services." In State v. Gonzalez, the court reversed the dismissal of charges against a psychiatric nursing assistant for inappropriately touching a patient, concluding that the allegations constituted sufficient criminal conduct. The defendant's role involved providing "treatment" and "assessment" through nursing tasks, which fell under the definition of "mental health services." The court cited a dictionary definition of "counseling" but did not determine if the defendant had provided counseling. Challenges to the statute's vagueness and overbreadth were rejected; the court asserted that the language clearly applied to the services Gonzalez provided, and no protected conduct was identified by him. The current appeal does not challenge the validity of the statute but instead questions the appropriateness of jury instructions regarding sexual exploitation by a counselor or therapist. The district court instructed the jury on the elements required to establish sexual exploitation, specifying the necessary intent and context of the defendant's relationship with the alleged victims. The term "counselor or therapist" was broadly defined to include clergy and others offering mental health services, while "mental health services" was defined as providing treatment, assessment, or counseling for various dysfunctions. Counseling relationships with clergy are specifically defined as aimed at addressing mental, intrapersonal, or interpersonal dysfunctions, excluding informal advice and general spiritual guidance. The jury received the statutory definition of mental health services from Iowa Code 709.15(1)(d) and was instructed that mental health services do not encompass informal advice. Instruction 25 clarified that the State had to demonstrate a formal counseling relationship, not just any counseling. The district court's instruction adapted elements from the defendant's requests while not fully incorporating them, particularly omitting a detailed definition of counseling based on modern psychological principles. The defendant argued that the jury should have been instructed that counseling required adherence to these principles for a conviction. However, the court found that 'counseling' is a term of ordinary usage and did not require a specialized definition unless it was deemed a technical term by the legislature. The court concluded that the legislature did not intend for 'counseling' to be viewed in such a technical manner. Statutes must be interpreted in their entirety, as established in State v. DeSimone. Iowa Code section 709.15 does not define 'counseling' in a specialized manner; it explicitly includes clergy, who typically do not engage in psychotherapy or modern psychological practices. The statute does not mandate that individuals providing mental health services be licensed or registered, and it encompasses those who merely claim to offer such services. Edouard acknowledges the variability in dictionary definitions of 'counseling,' indicating that the legislature did not intend to confine the term to contemporary psychological methods, as long as the individual addresses various dysfunctions. Previous case law under section 709.15 does not support Edouard's requested jury instruction. The conviction in Allen involved a hypnotherapist whose methods did not rely on modern psychology, and while informal advice was excluded from the statute, there was no requirement for contemporary psychological methods. The court's reliance on statutory definitions rather than dictionary definitions when addressing vagueness suggests a broader interpretation of 'counseling.' Edouard's challenge to Jury Instruction 25 is rejected, as the jury was correctly informed that each alleged victim had received mental health services from him, aligning with the statute's definition of 'patient or client.' His request for a list of all professions mentioned in section 709.15(1)(a) is deemed unnecessary, as the jury was adequately instructed that a 'counselor or therapist' includes clergy and others, regardless of state licensure. The court finds no error in these instructions. The district court's instruction accurately reflected the law, omitting irrelevant statutory portions. Edouard sought to introduce expert testimony from Dr. Hollida Wakefield, a forensic psychiatrist, to clarify the distinction between 'pastoral care' and 'pastoral counseling.' Dr. Wakefield indicated that pastoral care is a structured, time-limited response to specific problems, whereas Edouard’s interactions with four women did not meet the criteria for pastoral counseling. The court excluded her testimony, asserting it was responsible for instructing the jury on legal standards surrounding mental health services and that it was the jury's role to assess whether Edouard's conduct constituted providing such services. The admissibility of expert testimony is at the trial court's discretion, as established in State v. Hulbert. The court found no abuse of discretion, noting that Edouard aimed to use the expert to redefine the crime in question. Even unanimous agreement within the theological community about Edouard's actions not constituting pastoral counseling did not address whether they fit the statutory definition of mental health services. Historical cases were cited to support the exclusion of expert testimony that could confuse legal definitions or fail to clarify issues for the jury. The principles governing expert testimony admissibility require it to aid the jury in understanding evidence or determining factual issues, as per Iowa Rules of Evidence 5.702. The document addresses the criteria for determining whether Edouard's actions constituted mental health services under Iowa law. It emphasizes that the theological definition of such services is irrelevant to the legal framework. Dr. Wakefield’s proposed testimony, which included elements like a treatment plan and structured meetings, was excluded by the district court because these concepts are not defined in the relevant statute (section 709.15). Edouard argues there is insufficient evidence to support his guilty verdict. The court will consider all evidence favorably towards the State and will uphold a verdict if substantial evidence supports it, meaning there should be enough evidence to convince a rational jury of guilt beyond a reasonable doubt. Key facts include that all four women involved were members of Covenant Reformed Church and had sought Edouard’s counsel for personal issues, including marital problems. Edouard engaged in sexual relations with two women shortly after counseling sessions that involved deeply personal discussions. Specific evidence related to one woman, V.B., illustrates her emotional struggles with infertility and marital issues, which Edouard exploited, leading to a sexual encounter. Another woman, S.K., also sought Edouard's help amid her own marital difficulties and prior trauma in her family. Overall, the evidence presented raises significant concerns about Edouard's conduct in the context of the legal definitions of mental health services. S.K. experienced significant personal challenges, including marital issues and the recent death of her best friend. She confided in Edouard, a pastor, seeking support, which led to a series of meetings at her home where they became physically intimate. S.K. felt relief in sharing her husband's infidelities with Edouard, whom she trusted for confidential discussions. W.B. initially engaged in flirtatious conversation with Edouard, later seeking to end their interactions. During their meetings, Edouard's inquiries grew personal, eventually prompting W.B. to disclose her history of abuse, which he probed further. This interaction evolved into a sexual relationship, accompanied by Edouard's advice regarding marital counseling. A.B., who was dealing with depression and anxiety, perceived her meetings with Edouard as counseling sessions. Initially starting with general conversation, Edouard's questions became increasingly intrusive, causing A.B. discomfort. Despite her unease, she continued to meet with him, during which they also engaged in sexual relations. The document concludes that there is ample evidence to support Edouard's convictions for sexual exploitation, as he provided counseling to all four women for emotional or social dysfunctions, which falls under Iowa Code 709.15(1)(d). The district court's jury instructions established that Edouard's interactions with the victims went beyond mere informal advice or spiritual guidance, indicating a more involved relationship aimed at addressing specific mental and interpersonal issues. Evidence suggests that sexual contact formed part of Edouard's pseudotherapeutic practices. Following Edouard’s resignation, the four victims engaged in group therapy; while three waived their privilege regarding those records, W.B. did not. Despite this, the district court ordered the production of the records, which are not contested on appeal. Edouard sought access to W.B.'s counseling records to argue that she was not experiencing dysfunction, asserting that this would demonstrate he was not providing mental health services. However, the district court denied his request, ruling he failed to meet the burden of proof as established under the Cashen protocol and Iowa Code section 622.10, which requires a reasonable probability that the records contain exculpatory evidence. Edouard argued this denial violated his due process rights and claimed the district court misapplied the Cashen standard. Notably, a 2011 amendment to Iowa Code has revised the criteria for accessing privileged records, emphasizing the need for a compelling necessity and reasonable probability that the records contain unique exculpatory information. This amendment was applicable during the hearing on Edouard's motion for subpoena. In Neiderbach, the defendant and his codefendant faced charges of child endangerment after their son sustained severe injuries, including permanent brain damage, over a three-week period shortly after birth. The court found that the district court erred by not conducting an in camera inspection of the codefendant’s medical records, which Neiderbach claimed could provide exculpatory evidence critical to his defense. The credibility of the codefendant was pivotal, as Neiderbach's defense aimed to raise reasonable doubt about the source of the injuries, particularly given the codefendant's inconsistent statements and suspicious behavior. The court emphasized the potential value of the codefendant's mental health records for effective cross-examination. Despite recognizing the error, the court did not outright reverse Neiderbach’s conviction but ordered the district court to review the codefendant’s mental health records. If exculpatory evidence was found, a new trial would be considered; if not, the convictions would remain affirmed. In a related case involving Edouard, the court acknowledged the importance of maintaining the confidentiality of mental health records, particularly for victims. The court reiterated that a neutral judge should review such records to protect the victim’s constitutional right to privacy. This approach was deemed necessary to balance the rights of defendants and victims. Edouard's counsel attempted to leverage the testimony of W.B., a victim, during cross-examination regarding her marital counseling, but did not inquire into the specifics of those counseling sessions. W.B. testified that Edouard frequently inquired about her marriage counseling sessions, asking for details about the discussions and advice provided by her counselor at Pine Rest. She indicated that Edouard often disagreed with the counselor's advice and would suggest alternative approaches, which she tended to follow. The State contended that Edouard's pursuit of W.B.'s mental health records was unnecessary since she had asserted that her mental health was stable prior to their relationship, claiming that the records would not provide exculpatory information. However, it was noted that W.B. experienced personal difficulties after their relationship began, making records from that period potentially relevant. The State argued that a diagnosis of dysfunction was not essential for the crime but acknowledged that the absence of such a diagnosis could be pertinent for jury consideration. The State simplified the definition of "mental health services" to mean merely providing support for personal problems, while Edouard should have the opportunity to argue that it signifies something more significant, possibly impacting W.B.'s mental state at relevant times. Edouard must demonstrate a reasonable probability that the counseling records contain exculpatory information essential for his defense and that this information is not obtainable from other sources, as per Iowa Code 622.10(4)(a)(2)(a). The court referenced a prior case, Neiderbach, indicating that information may not be considered available simply because testimony could be obtained from the patient. The counseling records could potentially undermine W.B.’s testimony, prompting the reversal of the district court's denial of Edouard's request for in camera review of those records. The court noted the significance of the crime charged, which requires proof that Edouard counseled W.B. for a dysfunction, while also acknowledging that W.B. was receiving outside counseling concurrently. If no exculpatory evidence is found, Edouard’s convictions will remain affirmed; if such evidence is found, the district court will assess the necessity of a new trial concerning the relevant charges. Additionally, Edouard raises two constitutional challenges on appeal. He argues that Iowa Code section 709.15(2) unconstitutionally restricts his fundamental right to engage in sexual relationships, as it creates a blanket prohibition on sexual relations between specific individuals regardless of consent. Edouard maintains that the jury's not guilty verdict for sexual abuse indicates that his relationships with all four women were consensual. He contends that section 709.15(2) is not narrowly tailored to serve a compelling interest and does not use the least restrictive means. Although he references both the U.S. and Iowa Constitutional Due Process Clauses, he does not provide a distinct analysis under the Iowa Constitution, leading the court to apply the same reasoning for both claims. The court cites Lawrence v. Texas, where the Supreme Court recognized adults' rights to consensual private conduct under the Fourteenth Amendment but notes that this case is not analogous to situations where consent may be compromised or coerced. In State v. Musser, the Iowa Supreme Court upheld a statute making it a felony for an HIV-positive person to engage in intimate conduct with an unknowing partner, emphasizing that true consent requires awareness of such critical information. The court distinguished this case from Lawrence v. Texas, asserting that consent was not "full and mutual" when one partner was unaware of the other's HIV status. The ruling highlighted the serious risks of injury or death posed to the uninformed partner. The court noted similar dynamics in the cases involving Edouard, who exploited his authority as a counselor to manipulate four women, leading to harm and feelings of entrapment among them. These women expressed fear and distress following their experiences, indicating a lack of genuine consent due to the power imbalance in their relationships. The document further references various jurisdictions where similar arguments against sexual exploitation laws have been rejected, with courts reasoning that such statutes do not infringe upon fundamental rights and are distinguishable from the Lawrence decision due to the imbalanced nature of the relationships involved. Cases from Arizona, Arkansas, Kansas, Ohio, and Texas are cited, all supporting the view that sexual conduct laws can appropriately regulate relationships where true consent is compromised due to authority dynamics. A ban on relationships between teachers and students for one year post-graduation does not impose a direct and substantial burden on the right to intimate association and is subject to rational basis review, as indicated in Flaskamp v. Dearborn Pub. Schs. In contrast, Paschal v. State found that a law criminalizing sexual conduct between a teacher and an eighteen-year-old student infringed upon a fundamental right to privacy under the Arkansas Constitution. The New Hampshire Supreme Court in State v. Hollenbeck upheld a law prohibiting sexual relations between therapists and former patients within one year of ending therapy, determining that such relationships do not fall under the constitutional protection recognized in Lawrence v. Texas. The court concluded that these relationships can lead to exploitation due to the inherent power imbalance. The statute in question does not violate a fundamental right, as there is no right to engage in sexual relations where one party holds power over the other. The court noted that Edouard, the defendant, exercised authority over his victims, reinforcing the statute's applicability. While the court acknowledged that substantive due process challenges might arise in different contexts, Edouard did not contest the statute's vagueness or overbreadth. He also argued that the statute violated the Establishment Clause as applied to clergy members. The Minnesota Supreme Court's decision in State v. Bussmann revealed a split on whether clergy sexual conduct statutes violate the Establishment Clause, with a majority finding a violation based on the state's reliance on religious testimony that lacked secular grounding. The district court permitted the state to present extensive evidence concerning the Catholic Church’s teachings on the authority of priests, its counseling policies, concerns about priest misconduct, and its investigations into Bussmann’s actions. This evidence intertwined the Church's religious doctrines with legal standards for assessing Bussmann's criminal behavior under the clergy sexual conduct statute. The jury's verdict was influenced by this religious evidence. In State v. Wenthe, the Minnesota Supreme Court ruled that the clergy sexual conduct statute did not violate the Establishment Clause, stating it is part of a broader legal framework addressing power imbalances in relationships and applying neutral legal principles. The statute criminalizes sexual intercourse by clergy with individuals seeking spiritual guidance. The court confirmed the statute’s constitutionality in application, noting the state did not divert the jury’s focus from secular legal elements to religious doctrines. In contrast to the Bussmann case, Wenthe involved minimal church-related testimony and relevant evidence regarding the Church's pastoral policies. The analysis found that Iowa’s statute, while addressing clergy, is neutral and applicable to all mental health service providers. Relevant evidence about the victims' faith and Edouard’s role as their pastor was pertinent to understanding the victims’ consent dynamics. The trial did not emphasize religious doctrine excessively, maintaining focus on secular legal issues, which aligns with the court's findings in Wenthe. Edouard did not argue that Iowa’s sexual abuse statute infringed upon the Establishment Clause. The defendant aimed to introduce evidence regarding standards of pastoral care, while the State called only a psychologist as a rebuttal witness and two church elders, who primarily testified about admissions made in meetings regarding Edouard's conduct. During the cross-examination of the first elder, Edouard's counsel established that, while Edouard was expected to provide spiritual guidance, he was not responsible for mental health services. The court upheld an objection regarding the second elder’s concerns about the congregation, stating that the church's actions and positions were not relevant to the legal issues at hand, emphasizing the importance of maintaining boundaries between church matters and secular law. The court expressed skepticism about the relevance of any church findings impacting the jury's decision. Additionally, the State sought to exclude evidence of vandalism and harassment directed at Edouard's home after his misconduct became known, including incidents like a brick thrown through a window and his home listed for sale online. Edouard contended that such evidence was pertinent to explain his departure from the Pella community. However, the court deemed the evidence irrelevant and potentially confusing for the jury, stating it held little probative value, but remained open to reconsidering its admissibility if a clear basis for its relevance was established later. The defendant made an offer of proof regarding his evidence during the trial. Edouard reported multiple acts of harassment prior to the four women going to the police, including a rock thrown through his sons' bedroom window, spikes placed behind his vehicle wheels, his home and belongings listed for sale online, unsolicited pizza deliveries, and being followed by one victim's husband. These events prompted his decision to move to Michigan, as he felt unsafe and believed his presence was a source of conflict, impacting his children's well-being. He argued this context was relevant to explain his withdrawal from the church and abrupt relocation. However, the State contended that the jury did not require this explanation, given Edouard's admitted sexual relations with four married women from his congregation, which was sufficient for them to understand his departure. Edouard also sought to introduce evidence that one victim, V.B., engaged in an extramarital affair with another man, R.M., after their interactions and before her allegations against him. He argued this was relevant for demonstrating their friendship, the similarity of relationships, and the context of monetary gifts exchanged. The court ruled this evidence was inadmissible under Iowa's rape shield law, which protects victims' privacy and discourages irrelevant discussions about past sexual behavior, stating that such evidence could unjustly imply a consensual relationship with Edouard. The court emphasized the rule's purpose to uphold victims' rights and prevent distraction from the central issues of the case. Evidence of a victim's past sexual behavior, excluding reputation or opinion, is admissible when constitutionally required, as per Iowa Rule of Evidence 5.412(b)(1). This rule includes a balancing test, similar to Iowa Rule 5.403, to determine if the evidence's probative value outweighs its potential for unfair prejudice. If deemed relevant after a hearing as outlined in Rule 5.412(c)(2), the court may specify what evidence can be presented and what areas may be examined. The court has ruled that even relevant evidence of specific sexual conduct may be excluded if its prejudicial effect surpasses its probative value, as established in *State v. Mitchell* and *State v. Jones*. In this case, the court found questionable relevance in evidence of the victim's disclosed past sexual relationships, asserting it did not logically indicate a friendship over a counseling relationship. The victim's deceit about an affair and differing financial gifts did not substantially bolster the defense. The district court correctly ruled that evidence of the victim's alleged affair fell under the protection of the rape shield law, noting it could suggest a consensual relationship with Edouard based on her affair with another man. The ruling was upheld with no errors found. Additionally, Edouard argued against the restitution awarded to two women and their spouses, who received payments from the crime victim compensation program, which the State sought to charge against him. At the restitution hearing, the State presented testimony from the restitution subrogation coordinator of the crime victim assistance division and introduced six exhibits related to the victims and their spouses. The court subsequently ordered Edouard to pay a total of $12,956.74 in restitution. Citing State v. Jenkins, the court noted that amounts paid to victims by the Crime Victim Compensation Program (CVCP) cannot be automatically charged to a defendant without a review to confirm statutory causation requirements under Iowa Code section 915.86. Although the district court reviewed the case, Edouard argued the evidence was insufficient, claiming the State's witness lacked firsthand knowledge linking the victims' treatment to his conduct. The coordinator explained the process for approving compensation claims, which involves victims signing releases and providers verifying crime-related treatments. Each provider confirmed that their services were a direct result of Edouard’s crimes. Despite Edouard's vigorous cross-examination, he did not present any counter-evidence. The court clarified that strict rules of evidence do not apply in restitution proceedings and concluded that the mental health costs were substantiated by evidence as being incurred directly due to Edouard's actions. Additionally, Edouard contested the inclusion of travel expenses for trial attendance, arguing these should not be charged against him as they were costs of prosecution. Iowa Code section 915.86(15) allows victims and secondary victims to be compensated for reasonable expenses related to transportation for medical, counseling, or criminal justice proceedings, capped at $1,000 per person. The district court's award to the victims was deemed appropriate. Edouard's reference to State v. Knudsen was found irrelevant, as that case addressed prosecution costs, not the reimbursement for crime victim assistance, which is authorized under Iowa Code section 910.2(1). The court acknowledged that the State provided evidence supporting the victims' claims for trial attendance expenses. Edouard further argued that victims were ineligible for compensation under Iowa Code section 915.87(2)(a) due to their consent to their relationships with him. However, the trial court correctly determined this provision did not apply, emphasizing that the victims' mental health injuries stemmed from Edouard's conduct, not their consent. Edouard also contested the victims' compliance with limitations and reporting requirements in Iowa Code sections 915.84(1) and (2), which dictate a two-year application window and a 72-hour reporting window post-crime. He claimed that the victims did not report the crimes in a timely manner, as they used the date of their police reports as the crime date, despite the abuse occurring years earlier. The State argued that Edouard lacked standing to challenge the timeliness of the victims' claims, suggesting that the decision to award compensation lies between the agency and the applicants. However, the court maintained that to recover restitution from Edouard, the State must demonstrate compliance with the applicable laws. Defendants have the right to challenge incorrect CVCP payments, as established in Jenkins, 788 N.W.2d at 645. Although a state witness confirmed that a timeliness review is routinely conducted and a memo is created if an extension is granted, the memo is classified as confidential, and its existence in the current case was uncertain. The evidence provided is deemed inadequate to prove that the Department of Justice found good cause for any waivers of deadlines. If the evidence were sufficient, it would preclude any defendant from contesting timeliness. The court has not previously determined that Jenkins allows objections to CVCP restitution awards on the basis of deadlines not being waived for good cause. Therefore, the court decides to reverse and remand the case, allowing the State to present evidence regarding any deadline waivers under sections 915.84(1) or (2) for good cause. The court conditionally affirms Edouard's convictions and sentences under Iowa Code section 709.15(4)(a) and (4)(c) concerning W.B., while affirming other convictions but reversing the restitution award. The case is remanded for further proceedings in line with this ruling. The decision of the Court of Appeals is vacated, the district court's judgment is partially affirmed and partially reversed, and instructions for remand are provided. All justices concur, except for Appel, J. and Cady, C.J. who concur specially, and Hecht and Wiggins, JJ. who concur in part and dissent in part. Appel, Justice, concurs with Justice Mansfield's interpretation of Iowa's sexual exploitation statute but offers a distinct analysis regarding constitutional issues, stating that in cases involving both Iowa and Federal constitutional claims, the federal standard is generally applied unless a different standard is proposed, with the caveat that the court retains the discretion to apply it more stringently than federal precedent. The Iowa courts maintain the authority to interpret and apply the Iowa Constitution independently from federal constitutional standards, even when parties do not distinguish between the two. They reserve the right to deviate from federal interpretations and can impose stricter standards under the Iowa Constitution. This autonomy is supported by various case precedents, which affirm that Iowa courts may apply principles differently despite no substantive distinction being raised by the parties involved. The courts generally assume that the principles governing both state and federal provisions are similar, but they retain the option to adopt a different analytical framework, particularly in cases involving equal protection. Notably, the courts may reach different outcomes from federal cases when applying tests such as the rational basis test, though they may also align with federal interpretations based on their independent judgment. The distinction between a legal standard and its application is emphasized, particularly for broadly defined tests. The interpretation of state constitutional law often allows for a range of plausible answers rather than a single correct interpretation, necessitating case-by-case independent judgment. A majority of the court maintains that when both state and federal constitutional claims are presented, the federal standard generally applies, although a more stringent state standard may be adopted. Judge Sutton posits that the rationale behind using federal guarantees to interpret state guarantees is often unclear, suggesting that sister state decisions should be more influential given their historical and cultural similarities. In the case at hand, the court finds that Edouard has not established a distinct analysis under the Iowa Constitution, leading to the application of federal standards. The court concludes that the sexual exploitation statute does not infringe upon a fundamental right under the U.S. Constitution, referencing a similar conclusion in a New Hampshire case regarding non-consensual relationships. Furthermore, Edouard fails to demonstrate that the statute violates the Establishment Clause, aligning with Justice Mansfield's reasoning. The inclusion of religious figures in a related statute does not breach the Establishment Clause due to its regulatory nature over imbalanced sexual relationships. Ultimately, the court declines to adopt the substantive standards proposed by Edouard that deviate from existing Iowa case law. Legal standards from previous cases, Hollenbeck and Wenthe, are upheld regarding constitutional claims raised by Edouard under both the U.S. and Iowa Constitutions, leading to their rejection. Chief Justice Cady concurs with this decision, while Justices Wiggins and Hecht partially join in. Justice Hecht concurs with the majority reversal of the district court's denial of Edouard's request for an in-camera review of counseling records but dissents on other issues, arguing that Edouard suffered prejudice from the district court's jury instruction failures and the exclusion of essential expert testimony. Edouard, who served as pastor from 2003 to 2010, engaged in sexual relationships with four female congregants, which were disclosed in late 2010, leading to police reports in January 2011 after the women attended group therapy. He faced multiple charges, including sexual exploitation by a counselor or therapist and third-degree sexual abuse. Prior to trial, the State sought to limit Dr. Hollida Wakefield's expert testimony regarding the distinctions between pastoral care and counseling, which the district court ultimately excluded, deeming it unhelpful and potentially misleading. Edouard's defense rested on the argument that he did not provide mental health services as defined under the relevant statute. Edouard moved for a judgment of acquittal after the prosecution's case and renewed the motion at the trial's conclusion, arguing that the State did not provide sufficient evidence of sexual exploitation as defined by the statute. The district court denied both motions. After a ten-day trial, Edouard proposed a jury instruction detailing the definition of “counselor or therapist” under section 709.15(1)(a), emphasizing the necessity of a formal counseling relationship. He also sought an instruction stating that a conviction under section 709.15 required proof that one or more of the 60 women were his patients or clients, and a definition of “mental health services” consistent with prior cases. The district court refused these requests and provided its own less detailed instructions, which Edouard objected to. The jury convicted Edouard on four counts of sexual exploitation by a counselor or therapist and found him guilty of a pattern or practice count, but acquitted him on three counts of sexual abuse. Edouard appealed, challenging the district court's decisions regarding expert evidence and jury instructions, as well as raising additional evidentiary and constitutional challenges concerning section 709.15's application to clergy. The court of appeals determined that the trial court had abused its discretion by not providing Edouard’s proposed instruction on “mental health services,” concluding that he was prejudiced by this error, leading to a reversal of his convictions. The court noted an additional error in excluding parts of Dr. Wakefield’s testimony on pastoral care but did not address other challenges due to resolving the case on the instructional issue. Section 709.15 prohibits specified sexual conduct by a “counselor or therapist” with an “emotionally dependent patient or client” receiving “mental health services.” The definitions within the section include various professionals and clarify that “mental health services” encompass treatment, assessment, or counseling for dysfunctions. The ability to withhold consent is significantly impaired when a party is involved in a professional therapeutic relationship, as established under section 709.15(1)(b). Legal interpretations of this section require a comprehensive understanding of its language and intent, focusing on the specialized nature of "mental health services" rather than informal personal advice exchanges. In the case of State v. Allen, a woman with severe emotional issues sought help from an unlicensed hypnotherapist, who provided her with alcohol and engaged in inappropriate physical contact under the guise of therapy. Although the hypnotherapist did not deny acting as a counselor, he argued that the statute was unconstitutionally vague. The court clarified that section 709.15 does not encompass casual advice or ordinary conversations and generally does not apply to non-professional romantic relationships. The hypnotherapist's actions were deemed as part of a professional treatment relationship, leading to the affirmation of his conviction. In another case, State v. Gonzalez, the court further explored the definition of "mental health services" in the context of challenges to a defendant's professional role as a counselor. In Gonzalez, the defendant, a nursing assistant in a psychiatric unit, faced charges of sexual exploitation due to invasive contact with a female patient. The trial court dismissed the charges, concluding that the assistant did not provide mental health services as defined by Iowa Code section 709.15. The State appealed this decision. On appeal, the court analyzed the definitions of "treatment," "assessment," and "counseling" within the statutory context. The court determined that the nursing assistant's actions, such as caring for psychiatric patients and planning patient care, could reasonably qualify as "treatment" and "assessment." It was emphasized that these actions occurred while the patient was under psychiatric care, establishing a professional therapeutic relationship. Consequently, the court reversed the dismissal, indicating that the assistant's conduct might classify him as a "counselor" or "therapist" under the statute. The analysis clarified that section 709.15 addresses specific conduct within formal treatment relationships, highlighting the significance of the therapeutic environment and the necessity for an established professional relationship between the counselor and the patient. The statute's language implies that it governs only those interactions that rise to the level of a formal therapeutic relationship, particularly emphasizing the emotional dependency that must exist due to the nature of the treatment provided. The court's interpretation underscores that "treatment" involves formal medical or therapeutic actions, aligning with the statutory requirements for emotional exploitation charges. The civil damages provision establishes a five-year statute of limitations for claims related to sexual exploitation, beginning from the last treatment date by a counselor or therapist. The definition of "counselor or therapist" is strictly outlined and includes various licensed professionals such as physicians, psychologists, nurses, social workers, marriage and family therapists, and alcohol and drug counselors, all of whom have specialized training in mental health services. Clergy are also included in this category, with Iowa law permitting them to offer formal therapeutic services under certain conditions. The Iowa Code specifies the educational and licensing requirements for mental health professionals, ensuring that they provide services that address various mental health issues. Administrative rules further clarify the roles and responsibilities of these professionals in diagnosing and treating mental health disorders, emphasizing their specialized training and the importance of adhering to accepted standards within their respective fields. Section 709.15 of the Iowa Code delineates specific classes of professionals authorized to provide formal therapeutic and diagnostic services, indicating the statute's focus on relationships involving legitimate mental health treatment. The statute aims to criminalize misconduct within these formal treatment contexts, particularly when the accused claims to provide therapeutic services. Comparative analysis with statutes from other states reveals a spectrum of approaches regarding sexual exploitation laws. Some states, like Arkansas and Texas, have broader statutes that address exploitation without necessitating a formal therapeutic relationship, encompassing various professionals, including clergy and mandated reporters. In contrast, many states, including Connecticut and North Dakota, adopt narrower definitions that align more closely with Iowa’s statute, focusing specifically on established mental health providers and their designated roles. The text highlights that only a minority of jurisdictions explicitly criminalize exploitation by clergy outside of counseling settings, pointing out that Arkansas's law lacks detailed definitions and requirements present in Iowa's statute. This analysis underscores the complexity and variation in legislative approaches to sexual exploitation across states, emphasizing Iowa's more limited scope concerning therapeutic relationships. The statutes define mental health services and psychotherapy in terms of specific professional roles, such as clergy, emphasizing the technical nature of these relationships. Notably, the definition of “counselor or therapist” in section 709.15 does not necessitate state licensure and applies to anyone providing mental health services. However, this broad interpretation does not negate the need to consider the specific nature and context of the relationships involved, as demonstrated in previous cases like Gonzalez and Allen. The definition is intentionally limited; it does not generalize to “any person” or “any person in a position of power.” The principle of Noscitur a sociis suggests that the interpretation of terms should be informed by surrounding language, indicating that the statute is aimed at specific professional therapeutic relationships. A relevant case, State v. Ambrose, involved a high school teacher who engaged in a relationship with a student seeking help for depression, which eventually turned sexual. The court ruled that the statute did not apply to the teacher's actions due to a professionalism requirement in the definition of psychotherapy, which necessitated the use of formal therapeutic techniques. This highlights the need for a formal therapeutic context to establish a violation under the statute. The court analyzed a statute concerning the qualifications of professionals authorized to provide psychotherapy, specifically highlighting the roles of physicians, psychologists, social workers, marriage and family therapists, professional counselors, nurses, chemical dependency counselors, and clergy members. It concluded that psychotherapy is a specialized profession requiring formal training, which teachers typically do not possess. The court noted that the teacher in question did not present himself as a therapist, lacked training in psychotherapy, and was not compensated for any counseling he provided. Consequently, the court reversed the teacher's convictions, determining that his actions did not constitute professional psychotherapy. Furthermore, the analysis of Wisconsin's statute was deemed applicable to a similar statute under consideration. The author emphasized that the statute's narrow definitions, including specific professional categories and the requirement of a patient or client relationship, indicated it only pertains to formal therapeutic relationships. Any broader interpretation could lead to constitutional challenges related to vagueness and overbreadth, especially affecting clergy members. The majority's interpretation of the statute was criticized for not addressing these potential constitutional issues, despite Edouard's arguments regarding overbreadth and vagueness raised during the trial and on appeal. Edouard asserted that the statute could be interpreted to imply that anyone could possess a mental health dysfunction and that the prosecution's theory unfairly presumed an unequal power dynamic due to his clerical status. Edouard's constitutional analysis prominently references Roe v. Wade, highlighting its classification as an overbreadth case due to the Texas statute's failure to distinguish between early and late abortions. He argues that his appeal includes strong overbreadth and vagueness challenges. Specifically, Edouard questions the applicability of the Gonzalez definition of 'counseling,' suggesting that a clearer definition is necessary, supported by Knight v. Iowa District Court, which asserts that criminal acts must be clearly defined. He points out that the Roe decision did not address vagueness challenges because overbreadth was sufficient for the ruling. Edouard’s vagueness and overbreadth challenges cannot be treated separately, as they often overlap, particularly in cases involving fundamental rights, aiming to prevent the chilling of constitutionally protected expression and selective enforcement. Legal precedents recognize the relatedness of vagueness and overbreadth doctrines. The specificity required for vagueness challenges is heightened when First Amendment protections are at stake, suggesting that Edouard’s vagueness argument may be viewed as part of the broader overbreadth analysis. Edouard argues against the majority's broad interpretation of certain legal standards, emphasizing his right not to be subjected to an unconstitutional law. He asserts that an overbreadth claim is a personal assertion of rights, distinct from the rights of third parties, focusing on the individual's freedom from an invalid statute. Citing various legal precedents, he explains that an overbreadth challenge may reveal that a statute infringes on a significant amount of protected conduct. For example, a sexual exploitation statute was deemed unconstitutional because it could apply to various contexts involving clergy and congregants, potentially violating constitutional protections. The excerpt highlights the principle of constitutional avoidance, advocating for interpretations of statutes that do not lead to constitutional violations. It references relevant state legislation addressing sexual misconduct, noting that some recent laws may introduce constitutional entanglement issues due to their requirement for courts to interpret religious policies. Finally, it draws an analogy to medical malpractice, suggesting that professional standards, rather than religious beliefs, should guide legal interpretations in these contexts. Section 709.15 is explicitly limited to formal therapeutic relationships, as established in case law, including Gonzalez and Allen, which clarify that informal advice exchanges do not fall under this statute. The statute outlines specific criteria for a recognized professional relationship, such as the necessity for the actor to belong to defined professional categories and for the emotional dependence to stem from a specific emotional condition or treatment. Furthermore, the alleged victim must have been a patient or client, and the services provided must adhere to the statutory definition of "mental health services." In Edouard's defense, he argued that no formal treatment relationship existed with the State's witnesses and that he did not provide mental health services. The legal framework necessitates that the trial court instruct the jury on the relevant law concerning material issues, ensuring that correct legal principles are communicated. The district court's jury instructions required the State to prove specific elements of Sexual Exploitation by a Counselor or Therapist, including the defendant's engagement in sexual conduct with the alleged victim, intent, and the status of both parties as counselor/therapist and patient, respectively. The court defined "counselor or therapist" broadly, including clergy and others who provide mental health services, alongside a specific definition for "mental health services." Treatment, assessment, or counseling for cognitive, behavioral, emotional, mental, or social dysfunction is defined as requiring a formal therapeutic relationship, distinct from informal advice or spiritual guidance. Edouard contested the jury instructions for omitting critical elements, such as the "patient or client" requirement mandated by statute, which specifies that a formal relationship is necessary to establish mental health services. He argued that the court's instructions misrepresented the statutory definitions and failed to accurately reflect the necessary professional roles of counselors and therapists. On appeal, Edouard maintained that the district court abused its discretion by not adopting his proposed instructions, which he believed aligned with statutory requirements and relevant case law. The court's instructions acknowledged that the alleged victims had received mental health services from Edouard but lacked the explicit "patient or client" terminology, which is essential to comprehend the statute’s intent. Without this language, the jury could misunderstand the law, potentially concluding that Edouard's interactions with the women, as congregants, sufficed to meet the statutory criteria, thereby broadening the interpretation of the statute beyond its intended scope. The model 80 instruction committee advocates using both statutory terms and ordinary meanings in jury instructions, as jurors may better understand both. In the context of the term "involuntary servitude," it is argued that individuals—including jurors and prosecutors—can grasp its meaning as effectively as the phrase "slavelike condition." The author stresses that the statute should not be interpreted narrowly and that Edouard’s request for specific categories of mental health professionals in the definition of “counselor or therapist” would clarify the relationships governed by section 709.15. The definition encompasses officially recognized mental health providers while excluding others, emphasizing the necessity of a formal therapeutic relationship for the statute's application. Edouard’s omission from jury instructions regarding the statutory itemization led to an overly broad interpretation of the statute's scope. The principle of noscitur a sociis illustrates that the meaning of a word should be understood within its contextual associations. The importance of providing clear legal definitions to the jury, such as for “counseling,” “treatment,” and “assessment,” is highlighted, as these terms are critical for the jury to comprehend the technical aspects relevant to Edouard’s defense. Overall, the document underscores the need for precise language in legal instructions to ensure jurors have a proper understanding of the law and its implications. The Gonzalez definitions provide a general statutory meaning for section 709.15 and delineate acceptable interpretations of mental health services, specifically regarding formal therapeutic relationships. The district court's omission of these definitions in jury instructions risked a broad interpretation of the statute, leading to an error in refusing Edouard's proposed instructions. Such instructional errors necessitate reversal unless shown to lack prejudice, as previously established in relevant case law. The failure to instruct the jury on the distinct elements of a formal therapeutic relationship prejudiced Edouard's defense against accusations of engaging in the specified relationships. Additionally, the district court limited expert testimony from Dr. Wakefield on the differences between pastoral care and counseling, claiming it would be unhelpful and usurp the jury's role. However, Iowa case law supports a liberal view on the admissibility of expert testimony, regardless of whether it addresses ultimate issues. The court's responsibility to instruct the jury must be balanced with the evidentiary requirements, including the helpfulness of the testimony and the potential for misunderstanding legal terms. The limitations imposed on expert testimony raise concerns about meeting these evidentiary standards. The document emphasizes the importance of expert testimony in legal proceedings, particularly when it addresses subjects beyond the jury's common experience. It references various cases demonstrating that expert testimony is typically admissible when it aids the jury's understanding of complex issues, such as criminal behavior, business practices, or specific industry customs. For instance, expert insights on farming practices, police procedures, investment contracts, and franchise standards have been validated as beneficial to jurors. The excerpt also highlights the specific case of Dr. Wakefield’s testimony, which was deemed critical for providing context regarding the role of pastors in mental health services—an area where the jury may lack specialized knowledge. The district court's exclusion of this testimony was viewed as detrimental to the defense's case, as it denied the jury essential information relevant to Edouard's defense strategy. Overall, the text underscores that even testimony that seems within the jury's understanding can still be deemed helpful if it brings specialized knowledge to the discussion. Rule 702 testimony does not require the subject matter to be complex; rather, it is sufficient if it involves 'scientific, technical, or other specialized knowledge.' The admissibility of expert testimony hinges on whether the expert possesses unique knowledge or experience that aids the court or jury, regardless of the commonality of the subject matter. Courts recognize that even if fact finders have some knowledge, expert testimony can clarify incomplete or inaccurate understandings. In this context, Dr. Wakefield's expertise in differentiating between pastoral care and mental health counseling was deemed valuable for the jury to assess whether Edouard engaged in counseling as defined under section 709.15. Although jurors might possess some general understanding of pastoral duties, their grasp of the specific distinction likely lacked depth. Dr. Wakefield's insights could prevent misconceptions about the scope of counseling in pastoral contexts versus professional therapeutic relationships. The majority's dismissal of Edouard's request for Dr. Wakefield’s testimony mischaracterizes the intent, which was to provide specialized knowledge rather than to redefine mental health services. The defense sought to ensure that the jury applied the same definition of counseling relevant to other mental health professionals to Edouard's actions as a pastor, aligning with the statutory framework's principles. Thus, the expert testimony should have been admitted. Expert testimony can be vital for a court's understanding, particularly when no other evidence exists. In *Harris v. Pac. Floor Mach. Mfg. Co.*, the distinction was made between expert testimony that aids understanding and testimony about the adequacy of warnings that did not provide similar assistance. Dr. Wakefield's specialized knowledge was deemed crucial, as no other witness offered insights into the nature of mental health counseling provided by pastors to their parishioners. The significance of the testimony's subject matter is crucial in evaluating its helpfulness, as illustrated in *United States v. Alexander*, where excluding pertinent evidence affected the determination of guilt. The potential for jury confusion and the adequacy of the factual basis for testimony are also essential considerations. Experts must clarify their opinions and avoid using legal terminology that may confuse jurors. In *Palmer*, concerns arose when opinions did not link legal definitions to case facts, potentially leading to misunderstandings. When experts provide opinions without adequate criteria, jurors lack a basis to evaluate the testimony properly. Courts encourage experts to use layman’s language or to clarify specific meanings when legal and lay interpretations differ, as seen in *United States v. Duncan*. Dr. Wakefield aimed to minimize juror confusion regarding mental health services, employing accessible language similar to legal terms, as demonstrated by cases like *United States v. Nixon*. Ultimately, the clarity and relevance of expert testimony are pivotal in legal proceedings. Permitting the testimony of a narcotics officer regarding the quantity of cocaine discovered with the defendant at arrest, which could imply intent to distribute, is supported by precedent. Courts have allowed expert opinion testimony even when legal terminology is used, emphasizing that juries will understand the context and intent behind the terms rather than their strict legal definitions. Dr. Wakefield's testimony, which differentiates between pastoral care and pastoral counseling, is deemed non-confusing and relevant, contextualizing how pastors provide mental health services. Courts recognize the challenge of distinguishing admissible factual opinions from impermissible legal conclusions due to overlapping terminology, yet often admit such testimony for fairness and efficiency as long as it pertains to relevant issues and adheres to evidentiary rules. Dr. Wakefield's insights into the specialized tasks associated with pastoral roles are crucial for the jury's understanding and are deemed necessary for Edouard's defense, supporting the argument for her testimony's admissibility. Dr. Wakefield’s proposed testimony was critical in establishing that Edouard's role involved services akin to those provided by mental health professionals under section 709.15, relevant to Edouard’s defense that his actions were merely pastoral care and did not constitute mental health services as defined by the law. Courts have indicated that excluding such essential background information can lead to reversible error. Relevant case law supports the inclusion of expert testimony in similar contexts to clarify specific practices and responsibilities that may not be understood by the average juror. The distinction between pastoral care and pastoral counseling, as outlined in Dr. Wakefield’s testimony, posed minimal risk of confusion for the jury, particularly since the statute does not mention these terms. Her terminology and explanation of pastoral counseling were designed to mitigate any potential misunderstandings, as they aligned closely with the statutory definition of counseling. Furthermore, extensive testimony from Dr. Salter regarding the term "likely" indicated that her use of this term was appropriate and did not render her opinion inadmissible. Given the potential for jury confusion when statutory meanings diverge from expert testimony, the helpfulness and importance of Dr. Wakefield’s testimony to Edouard’s defense were evident. The district court's exclusion of this testimony was deemed an error, with the presumption that such evidentiary errors are prejudicial unless proven otherwise. For constitutional evidentiary errors, it is required that any alleged error be shown to be harmless beyond a reasonable doubt. The record does not definitively establish the absence of prejudice resulting from an error, regardless of its constitutional significance. The evidence in question would have provided crucial factual support for Edouard’s defense, demonstrating that he was not involved in the formal therapeutic relationships defined by the statute, and this evidence was not available from any other source. The instructional error exacerbated the situation, leaving the jury without essential factual and legal distinctions necessary for applying the relevant statutory principles. Consequently, the jury was deprived of critical information pertinent to the defense, which establishes prejudice and justifies a reversal of the decision. Additionally, the author supports a specific analytical approach for addressing issues under the Iowa Constitution in conjunction with related federal provisions and notes that Justice Wiggins partially joins in this concurrence while dissenting in part. The author refrains from discussing Edouard’s other appellate challenges, as the instructional and evidentiary issues are sufficient to determine the outcome.