Bruce Evan Martin, Applicant-Appellant v. State of Iowa
15-1622
| Iowa Ct. App. | Aug 17, 2016Background
- In 2004 Bruce Evan Martin pleaded guilty to one count of second-degree sexual abuse and one count of lascivious acts with a child; he was sentenced to concurrent indeterminate terms.
- Martin filed multiple postconviction-relief (PCR) applications: an initial PCR dismissed on summary judgment (no appeal), a second PCR tried and denied, a third PCR dismissed on summary disposition, and this fourth PCR based largely on alleged newly discovered agency documents.
- The State moved to dismiss the fourth PCR as time-barred under Iowa Code § 822.3 and as raising no new issues; the district court granted the motion after a hearing.
- Martin argued on appeal the documents underlying his fourth PCR were newly discovered, had not been available earlier, and thus he was entitled to an evidentiary hearing.
- The PCR court and this Court applied the § 822.3 exceptions for facts that could not have been raised earlier (e.g., newly discovered evidence) and the newly discovered evidence/new-trial standard.
- The Court concluded Martin failed to show the evidence was newly discovered or that it could not have been found earlier with reasonable diligence; some documents were previously in his possession and many claims had been or could have been raised earlier. The dismissal was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the fourth PCR is timely under Iowa Code § 822.3 or fits the newly discovered-evidence exception | Martin: Documents relied on were not in existence or available earlier, so the § 822.3 exception applies | State: Application filed outside 3-year limit and raises no ground that could not have been raised earlier | Held: Dismissal affirmed — Martin failed to show documents were newly discovered or that reasonable diligence could not have uncovered them |
| Whether the proffered documents create a genuine issue requiring an evidentiary hearing | Martin: Documents create new factual issues warranting a hearing | State: Documents do not undermine voluntariness of plea and many are cumulative or previously available | Held: No evidentiary hearing required; summary disposition appropriate |
| Standard for treating newly discovered evidence in PCR context | Martin: Newly discovered documents should permit collateral review despite plea | State: Standard mirrors new-trial analysis and requires showing evidence could not have been discovered earlier | Held: Court applies new-trial/newly discovered evidence framework; Martin fails the necessary diligence element |
| Whether any proffered evidence requires vacation of plea in interest of justice under § 822.2(1)(d) | Martin: Evidence warrants vacation of plea | State: Conviction after a valid guilty plea that met legal requirements cannot be overturned on this record | Held: Court rejects interest-of-justice claim; plea remains valid |
Key Cases Cited
- Manning v. State, 654 N.W.2d 555 (Iowa 2002) (standard for summary disposition in PCR actions)
- Castro v. State, 795 N.W.2d 789 (Iowa 2011) (standard of review for PCR proceedings)
- Perez v. State, 816 N.W.2d 354 (Iowa 2012) (interpretation of § 822.3 exception for grounds not raisable earlier)
- Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (requirements to prove facts could not have been raised earlier and nexus to conviction)
- State v. Weaver, 554 N.W.2d 240 (Iowa 1996) (newly discovered evidence/new-trial factors)
- State v. Romeo, 542 N.W.2d 543 (Iowa 1996) (newly discovered evidence analysis)
- State v. Sims, 239 N.W.2d 550 (Iowa 1976) (legislative intent that newly discovered-evidence standard applies in PCR and new-trial contexts)