Danny Wayne Rankins v. State of Iowa, 15-1423

January 18, 2006 armed robbery at an Arby’s in Des Moines; Rankins identified as getaway-car driver and later convicted of first-degree robbery.
A co-defendant (Randy Cason) was suspected; his charge was dismissed.
Rick Knutson signed an affidavit (April 15, 2006) stating he did not see Cason at the scene; the affidavit had been attached as an exhibit to a deposition before trial.
Rankins was sentenced to 25 years; direct appeal affirmed but ineffective-assistance issue reserved for postconviction relief; procedendo issued November 20, 2007.
Rankins filed a first postconviction-relief (PCR) petition in 2008 (denied and affirmed on appeal). He filed a second PCR petition on October 27, 2014; the State moved for summary judgment based on the three-year statute of limitations (Iowa Code § 822.3) and the district court granted summary judgment.
Rankins appealed, arguing the Knutson affidavit was newly discovered/exculpatory (an exception to the § 822.3 time bar) and that § 822.3 is unconstitutional as a suspension of habeas corpus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Knutson affidavit is newly discovered after judgment, tolling § 822.3	Rankins: Affidavit is newly discovered/exculpatory and was not available within the three-year period, so PCR is timely	State: Affidavit and its substance were known to Rankins before trial and before his first PCR; statute of limitations expired	Court: Affidavit was not newly discovered; Rankins knew contents before trial and first PCR; summary judgment proper
Whether § 822.3 violates habeas corpus (suspension)	Rankins: Three-year limitation unconstitutionally suspends habeas corpus	State: § 822.3 is constitutional	Court: Issue not preserved; alternatively, precedent (Davis) rejects argument; statute constitutional

Davis v. State, 443 N.W.2d 707 (Iowa 1989) (holding the three-year limitation on PCR does not violate the prohibition on suspension of the writ of habeas corpus)