Darrell Smith, Applicant-Appellant v. State of Iowa, 882 N.W.2d 126

Darrell Smith was convicted in 1997 of two counts of first-degree murder on alternate theories (premeditated murder and felony murder); jury returned a general verdict.
His convictions and prior postconviction-relief (PCR) actions were previously affirmed/denied on appeal.
Iowa law requires PCR actions be filed within three years of final conviction (Iowa Code § 822.3); Heemstra later clarified a legal rule relevant to murder/culpability.
In Heemstra, the Iowa Supreme Court announced a rule later held to be nonretroactive; Nguyen (2013) treated Heemstra as a new ground of law for statute-of-limitations purposes, allowing Nguyen’s PCR to proceed.
Smith filed a PCR application in 2014 asserting Nguyen created a new ground of law that would excuse his own statute-of-limitations bar, though Smith filed after Heemstra and only after Nguyen succeeded.
The district court dismissed Smith’s PCR as time-barred; the Court of Appeals affirmed without further opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nguyen created a new, independent ground of law that allows Smith to overcome the 3-year PCR statute of limitations	Smith: Nguyen’s holding (that Heemstra was a new ground) itself is a new ground enabling his delayed PCR	State: Nguyen does not create a separate, retroactive rule for others; Smith’s PCR remains time-barred	Court: PCR barred by 3-year statute; affirmed

State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (announced rule regarding culpability in certain homicide contexts)
Nguyen v. State, 829 N.W.2d 183 (Iowa 2013) (treated Heemstra as a new ground of law for statute-of-limitations purposes)