Martin Shane Moon v. State of Iowa
911 N.W.2d 137
Iowa2018Background
- In 1999–2000 Moon was tried and convicted of first‑degree murder based largely on testimony of co‑defendant Casey Brodsack; Brandon Boone was listed as a potential witness but did not testify.
- Boone later (2011 affidavit) admitted he had given false statements to law enforcement in 1998–1999 at Brodsack’s direction and in hopes of leniency on his own charges.
- Moon filed a second postconviction‑relief (PCR) application in 2012 alleging (1) a Brady due‑process violation for suppression of Boone materials and (2) newly discovered evidence requiring vacation of the conviction; the State moved for summary dismissal as time‑barred under the 3‑year statute.
- District court dismissed the PCR as untimely after applying the newly‑discovered‑evidence test (not the ground‑of‑fact test) and found Boone’s affidavit merely impeaching; the court did not resolve the Brady claim on the merits.
- Iowa Court of Appeals affirmed; Iowa Supreme Court granted further review, held the statute‑of‑limitations did not bar Moon’s substantive claims but rejected both the Brady and newly‑discovered‑evidence claims on the merits and affirmed the district court judgment.
Issues
| Issue | Plaintiff's Argument (Moon) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Moon’s PCR is time‑barred under Iowa Code § 822.3 (3‑year limit) | Boone’s affidavit is a new ground of fact unavailable within the limitations period so the exception applies | The application was filed after procedendo and is untimely | Court: Ground‑of‑fact exception applies as a genuine fact issue; statute does not bar merits review |
| Whether suppression of Boone materials amounted to a Brady violation | The State withheld interview reports/notes about Boone that were favorable/impeaching and material | Any withheld evidence was not material to guilt and would not have produced a reasonable probability of a different result | Court: Although suppression and favorability present genuine issues for hearing, the evidence was not material—no reasonable probability of different outcome; Brady claim fails |
| Whether Boone’s affidavit qualifies as newly discovered evidence under § 822.2(1)(d) | Boone’s admissions were discovered post‑trial, were unavailable earlier despite due diligence, and are material | The affidavit is at most impeachment/cumulative and would not probably change the verdict | Court: Elements (discovery timing and diligence) raise genuine issues, but evidence is merely impeaching and would not probably change result; newly‑discovered‑evidence claim fails |
| Whether impeachment alone can be "material" for PCR relief | Impeaching evidence can be Brady material if it undermines confidence in the verdict | Impeachment here is incremental; trial record already exposed major impeachment of Brodsack | Court: Impeachment can be material in Brady context generally, but here it was cumulative and would not undermine confidence in the verdict |
Key Cases Cited
- Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (ground‑of‑fact exception requires inability to raise claim earlier and a nexus to the conviction; court rejects requiring probable change in outcome to invoke exception)
- DeSimone v. State, 803 N.W.2d 97 (Iowa 2011) (Brady test elements and acknowledgment that impeachment evidence may be favorable)
- Bagley v. United States, 473 U.S. 667 (U.S. 1985) (Brady materiality standard: reasonable probability the result would have been different)
- Aguilera v. State, 807 N.W.2d 249 (Iowa 2011) (withheld DCI file could be exculpatory because it impeached witness credibility)
- Jones v. State, 479 N.W.2d 265 (Iowa 1991) (newly discovered evidence test and limits where defendant knew of evidence even if unavailable at trial)
- Cornell v. State, 430 N.W.2d 384 (Iowa 1988) (adoption of Bagley materiality standard and consideration of totality of circumstances)