The Iowa Supreme Court unanimously reversed a sex offender registry violation conviction against Joshua Kelly Uranga, ruling that the state failed to present sufficient evidence to support the charges under Iowa Code section 692A.105. The decision, filed February 13, 2026, vacates a Court of Appeals ruling and remands the case to district court with instructions to enter a judgment of acquittal.
Uranga was convicted of violating sex offender registry requirements for the second time, classified as a class D felony under Iowa Code section 692A.111(1). The conviction stemmed from charges under section 692A.105, which requires registered sex offenders to notify county sheriffs about temporary lodging away from their principal residence for more than five days.
The case originated in the Iowa District Court for Boone County, where Judge Bethany Currie presided over the trial. Uranga has been required to register as a sex offender since 2002, according to court documents.
Justice Oxley, writing for the unanimous court, identified a fundamental flaw in the state's prosecution. "The State presented no evidence, however, that Uranga stayed away from his principal residence for more than five days to trigger the registration requirement under section 692A.105," the court wrote.
Instead of proving the temporary lodging violation, the state based its prosecution on Uranga's failure to register his change in residence from Pilot Mound to Boone when his only Iowa residence changed. Such changes fall under Iowa Code section 692A.104, which addresses permanent residence changes rather than temporary lodging situations.
The court emphasized that section 692A.105 "does not impose any registration requirements in such a situation." This distinction between temporary lodging violations and permanent residence change violations proved critical to the court's analysis.
The decision highlights the importance of prosecutorial precision in sex offender registry cases. Iowa's sex offender registry law includes multiple provisions with distinct requirements and triggers. Section 692A.104 governs notification requirements when an offender changes their principal residence, while section 692A.105 specifically addresses temporary stays away from the principal residence exceeding five days.
Uranga was represented by Alexandar Smith of Parrish Kruidenier L.L.P. in Des Moines. The state was represented by Attorney General Brenna Bird and Assistant Attorney General Joseph D. Ferrentino.
The case followed a typical appellate path, beginning with the district court conviction, proceeding through the Iowa Court of Appeals, and ultimately reaching the state's highest court. The Iowa Court of Appeals had previously upheld the conviction, but the Iowa Supreme Court's review found the lower courts had erred in accepting insufficient evidence.
The unanimous nature of the decision underscores the court's view that the evidentiary deficiency was clear and significant. All justices joined Justice Oxley's opinion, indicating no dissent or separate concurring opinions were filed.
The reversal demonstrates the courts' requirement that prosecutors must prove each element of charged offenses with sufficient evidence. In sex offender registry violation cases, this means establishing not only that a defendant is subject to registry requirements, but also that specific triggering events occurred as defined by statute.
For temporary lodging violations under section 692A.105, prosecutors must prove the defendant stayed away from their principal residence for more than the five-day threshold. The absence of such evidence proved fatal to the state's case against Uranga.
The decision also illustrates the complexity of Iowa's sex offender registry law, which contains multiple overlapping provisions with distinct requirements. Legal practitioners handling registry cases must carefully distinguish between different violation types to ensure charges align with available evidence.
The remand to district court with instructions to enter a judgment of acquittal means Uranga's conviction is fully reversed. Unlike a remand for new trial, this instruction indicates the Iowa Supreme Court found the evidence insufficient as a matter of law, precluding retrial on the same charges.
This case may influence how prosecutors approach sex offender registry violation cases in Iowa, emphasizing the need to carefully match charges with available evidence and distinguish between different statutory provisions. Defense attorneys may also find the decision useful in challenging registry violation cases where evidence fails to establish required statutory elements.
The decision reflects broader principles of criminal law requiring prosecutors to prove every element of charged offenses beyond a reasonable doubt. Even in cases involving defendants with previous convictions, courts maintain strict evidentiary standards for new charges.