The Iowa Court of Appeals has affirmed the conviction of Robert Mitchell Farley for second-degree sexual abuse, third-degree sexual abuse, and willful injury resulting in bodily injury. This ruling, issued on May 27, 2026, impacts Farley, who will serve a 25-year prison sentence, and highlights significant issues surrounding the admission of evidence in sexual abuse cases.
The case stemmed from an incident on December 18, 2021, when Farley forcibly entered the victim's apartment after their relationship had ended. Following a jury trial in November 2024, Farley was found guilty of several charges, including two counts of sexual abuse. The court's decision to uphold the conviction addresses various claims raised by Farley regarding evidentiary rulings made during the trial.
Background
Robert Mitchell Farley and the victim had an on-and-off relationship for about three years. The victim, who had three children, ended the relationship after learning that Farley had impregnated another woman. On the night of the incident, the victim was asleep in her bedroom when Farley entered her home uninvited.
According to the victim’s testimony, Farley assaulted her, repeatedly slapping and strangling her while forcing her to engage in sexual acts. After the assault, the victim reported the incident to the police and underwent a sexual assault examination. Farley was charged with multiple offenses, including first-degree sexual abuse, which is a class “A” felony, as well as second-degree sexual abuse and willful injury.
The case went to trial in 2024, where the jury ultimately convicted Farley of second-degree sexual abuse, third-degree sexual abuse, and willful injury. He was sentenced to a total of 25 years in prison, with a mandatory minimum of 70 percent to be served before eligibility for parole.
The Ruling
The Iowa Court of Appeals reviewed several key issues raised by Farley in his appeal. First, the court addressed the exclusion of evidence related to the victim’s past sexual behavior. Farley argued that this evidence was crucial to his defense, claiming it could demonstrate consent. However, the court ruled that the district court did not abuse its discretion in excluding this evidence under Iowa’s rape shield law, which aims to protect victims' privacy and prevent irrelevant matters from being introduced in court.
The court stated, "We find no abuse of discretion in the district court’s ruling excluding evidence of the victim’s past sexual behavior under Iowa Rule of Evidence 5.412 and no reversible error in the court’s other evidentiary rulings."
Additionally, the court examined claims of improper vouching and character evidence. Farley contended that the testimony of a police officer and a nurse improperly vouched for the victim’s credibility. The court acknowledged that the police officer's testimony about the victim's demeanor was inadmissible but ultimately deemed the error harmless, given the overwhelming evidence supporting the victim's account.
Impact
This ruling has significant implications for sexual abuse cases in Iowa. By affirming the exclusion of the victim’s past sexual behavior, the court reinforced the importance of the rape shield law, which limits the introduction of potentially prejudicial evidence. This decision may influence how similar cases are handled in the future, particularly regarding the admissibility of evidence that could distract from the core issues of consent and assault.
The court's ruling also highlights the challenges defendants face when attempting to introduce evidence that they believe supports their case. The decision emphasizes that claims of past behavior must be substantiated with clear evidence to be considered by the court.
What's Next
Farley has the option to appeal the ruling to the Iowa Supreme Court, but it remains uncertain whether he will pursue this route. The outcome of this case could set important precedents for future sexual abuse trials in Iowa, particularly regarding evidentiary rulings and the rights of defendants to present their defense.