Raymond Lee Thomas Jr., Applicant-Appellant v. State of Iowa
16-0008
| Iowa Ct. App. | Jun 21, 2017Background
- Raymond Thomas Jr. was convicted of first-degree murder in 1995; conviction and sentence were affirmed on direct appeal in 1996.
- In 2014 (eighteen years later), Thomas filed his fourth application for postconviction relief (styled as a motion to correct an illegal sentence).
- Thomas argued he was 21 at the time of the crime and relied on research/precedent about delayed brain maturation to seek resentencing under juvenile-sentencing decisions.
- The State moved for summary disposition, arguing the application was time-barred under Iowa Code § 822.3 and that exceptions did not apply.
- The postconviction court granted summary dismissal; Thomas appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under § 822.3 | Thomas: delayed brain maturation is a new ground of fact excusing the 3-year bar | State: Thomas was 21 at offense; juvenile-development exception doesn't apply | Court: Time-bar applies; ground-of-fact exception inapplicable because precedents address juveniles, not adults |
| Ineffective assistance of postconviction counsel | Thomas: PCR counsel failed to move to amend, constituting structural/ineffective error | State: Cannot use PCR counsel error to evade statutory time bar | Court: Claims of PCR counsel error cannot circumvent the statutory limitations period |
| Legality of sentence under juvenile-sentencing precedent | Thomas: Cites Miller/Lyle—sentence illegal because of brain development principles; seeks resentencing | State: Precedent on juvenile sentencing does not extend to adult offenders | Court: Juvenile-sentencing precedents do not apply to adults; sentence legality challenge fails |
| Need for further fact development | Thomas: Court should develop record on brain-maturation evidence | State: No basis for development because exception doesn't apply | Court: No factual development required; summary disposition proper |
Key Cases Cited
- State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (discusses juvenile brain development and parole prospects)
- State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (holds mandatory youthful-offender minimums unconstitutional under state constitution)
- Smith v. State, 542 N.W.2d 853 (Iowa Ct. App. 1995) (PCR counsel error cannot be used to evade statutory time limits)
- State v. Wilkins, 522 N.W.2d 822 (Iowa 1994) (rejects labeling claims ineffective-assistance to reach untimely merits)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (Eighth Amendment prohibits mandatory life-without-parole sentences for juveniles)