The Iowa Court of Appeals has upheld a ruling that prevents Patrick Edouard’s ability to review one of his victim’s medical records in an attempt to get his case re-examined.
Edouard is serving a five year prison sentence for four counts of sexual exploitation and one count of pattern, practice, or scheme to engage in sexual exploitation. The former pastor in Pella was found guilty on October 19, 2012, after a joint investigation by the Pella Police Department and the Marion County Sheriff’s Office. He was accused of maintaining relationships with members of his congregation.
According to court records, Edouard appealed the Marion County District Court’s determination that confidential medical records of one of his victims he sought to discover contained no exculpatory evidence. The Iowa Supreme Court ordered a review of the records for evidence after an in-camera review for Edouard was denied by the trial court.
The review occurred after the Supreme Court’s ruling, and the district court determined there was no evidence. Edouard argues his due process and confrontation rights have been impaired by the record-review procedure. The Court of Appeals upheld the process utilized by the Marion County District Court.
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