Martin Shane Moon, Applicant-Appellant v. State of Iowa, 15-1815

Martin Moon was convicted of first-degree murder in 2000; conviction affirmed on direct appeal and procedendo issued July 2002.
Moon filed a first PCR in 2002; it was denied and that denial was affirmed in 2007.
In January 2012 Moon filed a second PCR claiming newly discovered evidence: an affidavit from Brandon Lee Boone recanting prior statements that had implicated Moon and alleging those statements were made at the direction of Casey Brodsack.
Boone had been listed in the minutes of testimony as a potential State witness but did not testify at trial; Brodsack did testify against Moon after pleading guilty to second-degree murder in exchange for testimony.
Moon argued he lacked earlier access to Boone’s recantation (invoking the ground-of-fact exception to Iowa’s three-year PCR statute of limitations) and also asserted Brady-like suppression of Boone’s statements.
The district court granted the State’s motion for summary dismissal based on the statute of limitations; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Moon’s 2012 PCR is time-barred under Iowa Code § 822.3	Boone’s 2011 affidavit is a newly discovered ground of fact that could not have been raised within three years	The PCR is barred by the three-year statute; Boone’s affidavit is not a qualifying ground of fact	Affirmed: time-bar applies; Boone’s affidavit fails the ground-of-fact exception
Whether Boone’s affidavit satisfies the ground-of-fact nexus requirement	Affidavit shows Brodsack coerced Boone to implicate Moon, which could affect the conviction	Affidavit only impeaches Brodsack and lacks potential to be material evidence affecting conviction	Held: affidavit lacks necessary nexus; only impeaching/cumulative
Whether non-disclosure of Boone’s statements amounted to a Brady violation justifying late filing	Moon claims he never received police reports of Boone’s statements and was prejudiced	State noted Boone was disclosed in minutes; Moon was aware Boone was uncooperative before trial	Held: Court treated the claim as insufficient to meet the exception; Brady argument did not overcome limitations bar
Whether summary dismissal was appropriate	Moon sought to proceed on merits of newly discovered evidence claim	State moved for summary dismissal under the statute of limitations	Affirmed: summary dismissal proper because exception not met

Castro v. State, 795 N.W.2d 789 (Iowa 2011) (standard of review for summary dismissal of PCR and analysis of limitations exceptions)
Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (defines ground-of-fact exception and nexus requirement for tolling PCR limitations)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution suppression of material favorable evidence violates due process)