Adnan Sahinovic v. State of Iowa, 940 N.W.2d 357

In 2011 Adnan Sahinovic pled guilty to second-degree robbery (class C felony) and forgery; judgments became final July 5, 2011. He was sentenced to concurrent terms (robbery 10 years with 7/10 mandatory before parole eligibility).
In Jan 2014 Sahinovic moved to correct an illegal sentence, arguing his mandatory minimum was illegal because he was 17 at the time of the offense (relying on Lyle). New counsel attempted to recast that motion as a postconviction-relief (PCR) petition adding a Padilla ineffective-assistance/immigration consequence claim attacking the plea.
The district court refused to recast the motion; in April 2015 the court granted the illegal-sentence motion and resentenced Sahinovic to immediate parole eligibility but expressly declined to address the plea challenge in that proceeding.
Sahinovic then filed a separate PCR petition in Aug 2015 challenging his guilty plea; the State moved for summary judgment asserting Iowa Code § 822.3’s three-year statute of limitations had expired (three years from finality in 2011).
The district court and court of appeals dismissed the PCR petition as time-barred; the Iowa Supreme Court granted review to decide whether resentencing restarts the § 822.3 limitations period for challenges to an underlying conviction.

Issue	Plaintiff's Argument (Sahinovic)	Defendant's Argument (State)	Held
Whether resentencing restarts the 3-year limitations period in Iowa Code § 822.3 for collateral attacks on the underlying conviction	Resentencing is part of the conviction/sentence package; because one cannot appeal a conviction until sentenced, resentencing restarts the § 822.3 clock	"Conviction or decision" refers to the finality of the specific determination being attacked; Sahinovic’s convictions became final in 2011, so the limitations period expired in 2014	Held: Resentencing that does not disturb the finality of the conviction does not restart the § 822.3 limitations period for attacking the conviction; petition dismissed as time-barred
Whether Sahinovic’s reliance on Daughenbaugh supports treating his conviction as non-final after resentencing	Daughenbaugh shows conviction/sentence are interrelated and that conviction timing can affect PCR eligibility	Daughenbaugh addressed deferred judgments (no final conviction); it does not imply that a collateral resentencing erases finality—conviction remained final here	Held: Daughenbaugh is distinguishable; "conviction" in chapter 822 means a conviction that is final; collateral resentencing did not disturb finality and did not trigger a new § 822.3 period. The Court noted a different result might follow if resentencing occurred as part of a direct appeal.

Daughenbaugh v. State, 805 N.W.2d 591 (Iowa 2011) (deferred-judgment context: no final conviction for PCR eligibility)
Davis v. State, 443 N.W.2d 707 (Iowa 1989) (upholding constitutionality and purpose of three-year PCR statute)
Lyle v. State, 854 N.W.2d 378 (Iowa 2014) (juvenile offender sentencing implications relied on for illegal-sentence claim)
Padilla v. Kentucky, 559 U.S. 356 (2010) (counsel’s duty to advise re: immigration consequences in plea context)
Brewer v. Iowa Dist. Ct., 395 N.W.2d 841 (Iowa 1986) (historical note on enactment of PCR statute of limitations)
People v. Metcalf, 979 P.2d 581 (Colo. App. 1999) (persuasive authority refusing to restart collateral-attack limitations after resentencing)