Jacob Lee Schmidt v. State of Iowa
909 N.W.2d 778
Iowa2018Background
- In 2007 Jacob Schmidt pleaded guilty to assault with intent to commit sexual abuse (aggravated misdemeanor) and incest; the plea was accepted after a detailed colloquy and he was sentenced. He did not appeal.
- Years later (2014) Schmidt filed a postconviction-relief (PCR) application claiming actual innocence based on the victim B.C.’s recantation (affidavit stating he later told people the abuse did not occur).
- The State moved for summary dismissal/summary judgment arguing (1) the three-year PCR statute of limitations barred the petition and (2) Schmidt cannot use newly discovered/exculpatory evidence to attack a knowing, voluntary guilty plea.
- The district court granted the State’s motion (relying on precedent that new evidence extrinsic to a plea cannot defeat a plea), and the court of appeals affirmed. The Iowa Supreme Court granted further review.
- The Iowa Supreme Court overruled prior Iowa precedent to hold the Iowa Constitution permits freestanding claims of actual innocence that can be brought after a guilty plea; it adopted a clear-and-convincing standard for such claims and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a defendant who knowingly and voluntarily pleaded guilty may bring a postconviction freestanding claim of actual innocence | Schmidt: Iowa Constitution and §822.2 permit a freestanding actual-innocence claim to attack a plea | State: Guilty plea waives all non-intrinsic challenges; recantation is extrinsic and cannot undo a knowing voluntary plea | Held: Court recognizes freestanding actual-innocence claims under Iowa Constitution and §822.2 can be asserted after a guilty plea |
| Standard of proof for freestanding actual-innocence claims after a plea | Schmidt: relief should be available (argued lower standard) | State: high burden required to protect finality of pleas | Held: Applicant must prove by clear and convincing evidence that, in light of all evidence (including new evidence), no reasonable factfinder could convict |
| Whether the three-year PCR statute of limitations bars Schmidt’s application | Schmidt: recantation is newly discovered and could not have been raised earlier | State: claim discoverable earlier; limitations applies | Held: The §822.3 ground-of-fact exception applies here — recantation not discoverable within three years, so limitations does not bar the claim |
| Appropriate procedural vehicle and next steps on summary disposition | Schmidt: PCR §822 is proper vehicle; merits unresolved | State: summary judgment appropriate based on plea colloquy and existing record | Held: §822 provides an appropriate vehicle; case remanded to district court to apply the new standard and permit supplementation of the record before ruling on summary disposition |
Key Cases Cited
- State v. Utter, 803 N.W.2d 647 (Iowa 2011) (prior Iowa rule precluding extrinsic challenges to guilty pleas)
- Tollett v. Henderson, 411 U.S. 258 (1973) (guilty plea generally bars later challenges inconsistent with plea)
- State v. Alexander, 463 N.W.2d 421 (Iowa 1990) (held new-trial rule did not permit new-trial after guilty plea; referenced postconviction relief as possible avenue)
- Schlup v. Delo, 513 U.S. 298 (1995) (federal gateway actual-innocence standard: more-likely-than-not standard for procedurally defaulted claims)
- Ex parte Tuley, 109 S.W.3d 388 (Tex. Crim. App. 2002) (permitting freestanding actual-innocence claims after plea; clear-and-convincing standard adopted by some jurisdictions)
- House v. Bell, 547 U.S. 518 (2006) (discussion of actual-innocence standards and demands of proof)