Nick C. Rhoades v. State of Iowa
2016 Iowa Sup. LEXIS 47
| Iowa | 2016Background
- Nicholas Rhoades, HIV-positive, engaged in consensual sexual contact with A.P.; he pled guilty to criminal transmission of HIV and was sentenced (later placed on probation).
- Rhoades moved for postconviction relief alleging ineffective assistance and lack of factual basis for the guilty plea; Iowa Supreme Court reversed, holding the record lacked a factual basis for the statutory element of "intimate contact." (Rhoades v. State)
- On remand the State dismissed the charges. Rhoades then sued under Iowa's wrongful imprisonment statute (Iowa Code ch. 663A) seeking compensation.
- Iowa Code § 663A.1(1)(b) bars compensation for anyone who "pled guilty to the public offense charged"; the district court dismissed Rhoades’ claim on that basis.
- The central legal question: whether a later-vacated or legally-invalid guilty plea nevertheless disqualifies a claimant from relief under Iowa’s wrongful imprisonment statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a vacated/invalid guilty plea bars recovery under Iowa Code § 663A.1(1)(b) | Rhoades: an invalid/void guilty plea is a nullity and should not disqualify him from seeking wrongful-imprisonment compensation | State: the statute’s plain language excludes anyone who pled guilty, regardless of later vacatur | The court held the statute categorically excludes all who pled guilty; Rhoades cannot pursue a claim under ch. 663A |
| Whether Rhoades has proven actual innocence required by § 663A.1(2) | Rhoades implied dismissal shows innocence; he urged remand to pursue compensation | State: dismissal by the prosecutor does not establish actual innocence | Court: Rhoades has not shown actual innocence by clear and convincing evidence; at best he’s entitled to a remand to attempt to prove it, but statutory disqualification ends the claim |
| Proper method of statutory interpretation when plea-language is ambiguous | Rhoades: follow courts (Ohio appellate) treating void pleas as nullities for compensation eligibility | State: read text literally to limit fiscal exposure and preserve finality of plea bargains | Court: considered text, context, legislative practice, policy and concluded legislature intended a categorical bar for guilty pleas |
| Whether legislative intent evidence (sponsor affidavit) can be used | Rhoades relied on sponsor affidavit arguing statute aimed at procedurally vacated convictions | State: affidavit inadmissible | Court: rejected sponsor affidavit; held legislator affidavits inadmissible for legislative intent |
Key Cases Cited
- Rhoades v. State, 848 N.W.2d 22 (Iowa 2014) (appellate decision finding insufficient factual basis for Rhoades’s guilty plea)
- Dunbar v. State, 992 N.E.2d 1111 (Ohio 2013) (Ohio Supreme Court held vacated guilty plea still disqualifies under Ohio statute)
- State v. Boone, 298 N.W.2d 335 (Iowa 1980) (guilty plea that is not voluntary and knowing may be void)
- McCarthy v. United States, 394 U.S. 459 (1969) (Supreme Court discussion characterizing involuntary pleas as void)
- Moore v. State, 847 N.E.2d 452 (Ohio Ct. App. 2006) (Ohio appellate court treated void plea as nullity for wrongful-imprisonment eligibility)
- State v. DeSimone, 839 N.W.2d 660 (Iowa 2013) (Iowa wrongful-imprisonment statutory interpretation and standards)
- State v. McCoy, 742 N.W.2d 593 (Iowa 2007) (actual-innocence burden under Iowa § 663A.1(2))
- State v. Dohlman, 725 N.W.2d 428 (Iowa 2006) (clarifying two-step analysis under Iowa’s wrongful-imprisonment statute)