Lawrence Gladson, Applicant-Appellant v. State of Iowa, 15-1017

Lawrence Gladson was convicted in 1986 of first‑degree murder (life) and three counts of first‑degree robbery (three consecutive 25‑year terms); convictions affirmed on direct appeal.
Gladson filed prior postconviction relief (PCR) actions in 1992 and 2008 that were denied.
He filed a third PCR application in June 2014, arguing recent Iowa cases altered the law governing joint‑criminal‑conduct jury instructions and thus his claim was timely under the three‑year PCR statute of limitations.
At the PCR hearing, Gladson’s counsel and the State agreed the court could take judicial notice of the underlying criminal file; no other evidence was presented.
The district court dismissed the PCR as barred by the three‑year limitations period (Iowa Code § 822.3) and found State v. Smith did not represent a change in law on joint criminal conduct beyond preexisting precedent.
Gladson also claimed ineffective assistance of PCR counsel for failing to identify specific items judicially noticed; the court declined to reach that claim after finding the application time‑barred.

Issue	Gladson's Argument	State's Argument	Held
Whether Smith (and Nguyen) created a new ground of law tolling the 3‑year PCR limitations period	Smith (and Nguyen) changed/clarified joint‑criminal‑conduct law such that Gladson’s claim could not have been raised earlier	Smith did not change the law; prior case Irvin already articulated the rule; Nguyen does not alter § 822.3 limitations	Dismissed as time‑barred: Smith did not constitute a new ground sufficient to avoid the 3‑year bar and Nguyen did not change the limitations rule
Whether the PCR court erred in taking judicial notice of the criminal file without a specific citation and whether PCR counsel was ineffective for that failure	PCR counsel was ineffective for not identifying the specific judicially noticed items, undermining the record	Judicial notice by agreement was permissible; even if deficient, the claim is moot because of statute‑of‑limitations dismissal	Court did not reach ineffectiveness claim on merits because the PCR was properly dismissed as time‑barred

State v. Smith, 739 N.W.2d 289 (Iowa 2007) (discusses elements for joint‑criminal‑conduct liability and suggested jury‑instruction language)
Nguyen v. State, 829 N.W.2d 183 (Iowa 2013) (addresses retroactivity and timing of postconviction claims based on intervening changes in law)
State v. Irvin, 334 N.W.2d 312 (Iowa Ct. App. 1983) (articulated joint‑criminal‑conduct rule relied on by the court as preexisting law)
Perez v. State, 816 N.W.2d 354 (Iowa 2012) (discusses limits of claiming a decision is both a clarification and a new ground to overcome the PCR statute of limitations)
State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (example of a case recognized as changing law for purposes of PCR timeliness analysis)