Jacob Lee Schmidt v. State of Iowa

IN THE SUPREME COURT OF IOWA No. 15–1408 Filed March 23, 2018 JACOB LEE SCHMIDT, Appellant, vs. STATE OF IOWA, Appellee. On review from the Iowa Court of Appeals. Appeal from the Iowa District Court for Woodbury County, Edward A. Jacobson, Judge. A defendant seeks further review of a court of appeals decision affirming summary dismissal/summary judgment of his postconviction- relief action. DECISION OF COURT OF APPEALS VACATED; DISTRICT COURT JUDGMENT REVERSED AND CASE REMANDED. Mark C. Smith, State Appellate Defender, and Martha J. Lucey, Assistant Appellate Defender, for appellant. Thomas J. Miller, Attorney General, Sheryl Soich, Assistant Attorney General, for appellee. 2 Erica A. Nichols Cook of the State Public Defender’s Office, Des Moines, for amicus curiae Exoneration Project at the University of Chicago Law School. Lance W. Lange, Jesse Linebaugh, and Mitch G. Nass of Faegre Baker Daniels, LLP, Des Moines, for amici curiae The Innocence Network and The Innocence Project of Iowa. 3 WIGGINS, Justice. An applicant filed a postconviction-relief action claiming he was actually innocent although he knowingly and voluntarily pled guilty to the charged crimes. He based his actual-innocence claim on a recantation by the victim. The district court granted the State’s motion for summary dismissal/summary judgment, ruling the applicant cannot use the recantation to attack his knowing and voluntary guilty pleas because the recantation was extrinsic to the pleas. The applicant appealed, and we transferred the case to our court of appeals. The court of appeals affirmed. The applicant sought further review, which we granted. On further review, we overrule our cases holding that defendants may only attack the intrinsic nature—the voluntary and intelligent character—of their pleas. We now hold the Iowa Constitution allows freestanding claims of actual innocence, so applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily. Accordingly, we adopt a freestanding claim of actual innocence that applicants may bring under our postconviction- relief statute. 1 Therefore, we vacate the decision of the court of appeals, reverse the judgment of the district court, and remand the case to the district court for further consideration consistent with this opinion. I. Background Facts and Proceedings. On December 19, 2006, the State filed a trial information charging Jacob Lee Schmidt with sexual abuse in the third degree in violation of 1We do not think Class v. United States, 583 U.S. ___, 138 S. Ct. 798 (2018), affects our decision today. In that case, the United States Supreme Court held a guilty plea does not bar a federal criminal defendant from challenging on direct appeal the constitutionality of the statute of conviction. Id. at ___, 138 S. Ct. at 803–05. Our decision involves an actual-innocence claim under the Iowa Constitution based on newly discovered evidence. 4 Iowa Code section 709.4(1) (2005). On March 23, 2007, the State moved to amend the trial information to charge Schmidt with two additional counts of sexual abuse in the third degree in violation of section 709.4(2)(b) (counts II and III) and ...

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