State v. Wilson
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The defendant, Christopher James Wilson, was charged with two counts of indecent exposure after he was seen masturbating in public by two women, E.H. and T.A., at a gas station. Wilson followed the women to another location where he continued his actions. He was subsequently arrested and charged. After a jury trial, he was convicted on both counts and sentenced to an enhanced sentence under Iowa Code section 901A.2(1) to an indeterminate prison term of two years for the first count and an indeterminate prison term of two years for the second count. The sentence for count one was ordered to run consecutively to the sentence for count two.
Wilson appealed his conviction and sentence, arguing that the unit of prosecution for indecent exposure is per exposure, not per viewer. Therefore, he contended that there was insufficient evidence to convict him on two separate counts of indecent exposure. He also argued that the district court did not provide sufficient reasons for imposing a consecutive sentence under Iowa Rule of Criminal Procedure 2.23(3)(d).
The Supreme Court of Iowa affirmed the lower court's decision. The court held that the unit of prosecution for indecent exposure is one count per viewer, not one count per exposure. Therefore, there was sufficient evidence to support a conviction on two counts of indecent exposure. The court also found that the district court provided sufficient reasoning for imposing a consecutive sentence. The court noted that the district court's reasoning for imposing consecutive sentences may be the same reasons the court relied on for the imposition of incarceration. The court concluded that the district court's statement that the only appropriate sentence was to send Wilson to prison for as long of a period of time as possible implied that the sentences should run consecutively.
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