Edward A. Grayson, Applicant-Appellant v. State of Iowa
15-1382
| Iowa Ct. App. | Nov 9, 2016Background
- Edward Grayson was convicted by jury in 1996 of first-degree kidnapping and later filed multiple postconviction-relief (PCR) applications.
- The PCR at issue was filed April 9, 2015, nearly 17 years after the procedendo from his direct appeal.
- The district court dismissed the 2015 PCR as untimely under Iowa Code § 822.3 (three-year limitations period).
- Grayson argued the court should allow the untimely PCR because of an "actual innocence" exception (relying on federal habeas precedent).
- Grayson’s asserted actual-innocence claim relied on the victims’ trial testimony and his reading of State v. Robinson as announcing a new rule narrowing what constitutes kidnapping.
- The Court of Appeals affirmed: it assumed (without deciding) Iowa might adopt a federal-style actual-innocence gateway but held Grayson presented no new, reliable evidence that would satisfy that demanding standard; it also treated Robinson as a clarification, not a new rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iowa's § 822.3 limitations period is subject to an "actual innocence" exception | Grayson: actual-innocence exception should allow PCR even if claim could have been raised earlier | State: PCR is time-barred under § 822.3; error-preservation issues too | Court assumed arguendo the exception but found Grayson failed the demanding Schlup/McQuiggin standard because he offered no new reliable evidence; PCR dismissed as untimely |
| Whether State v. Robinson announced a new rule that would excuse untimeliness | Grayson: Robinson changed the law on kidnapping confinement element, supporting actual innocence | State: Robinson did not announce a new rule that would retroactively justify delay | Court agreed Robinson clarified existing law (Rich test) rather than announcing a new rule; claim not saved by any new-rule doctrine |
Key Cases Cited
- Schlup v. Delo, 513 U.S. 298 (establishing demanding actual-innocence gateway standard in federal habeas)
- McQuiggin v. Perkins, 569 U.S. 383 (recognizing actual-innocence gateway but stressing the Schlup standard is demanding)
- State v. Robinson, 859 N.W.2d 464 (Iowa 2015) (addressed confinement requirement for kidnapping; treated here as clarification)
- State v. Rich, 305 N.W.2d 739 (Iowa 1981) (three-factor test referenced in Robinson)
- State v. Miller, 841 N.W.2d 583 (Iowa 2014) (noting role of Iowa Supreme Court in overruling precedent)