Robert Jackson White, Applicant-Appellant v. State of Iowa, 16-0161

Robert Jackson White was convicted in 2009 of possession with intent to deliver as an habitual offender after a jury trial; conviction was affirmed on direct appeal.
In October 2015 White filed a postconviction-relief (PCR) application more than three years after his conviction became final.
The State moved for summary judgment, arguing White’s PCR application is time barred by Iowa Code § 822.3 (three-year limitations period).
White argued the Iowa Supreme Court’s decision in State v. Gaskins constituted new law that could not have been raised earlier and thus tolled the statute of limitations for his PCR claim.
White contended Gaskins made the search of his vehicle (and resulting home seizure) illegal, but the PCR court found the automobile-exception to the warrant requirement applied in his case and that Gaskins did not change that analysis.
The PCR court granted summary judgment to the State; the Court of Appeals affirmed, concluding White failed to show a nexus between Gaskins and the validity of his conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gaskins is ‘‘new law’’ excusing untimely PCR under § 822.3	Gaskins created a new ground of law that could not have been raised within the limitations period	Gaskins does not apply to White’s case because the automobile exception still justified the search; thus no tolling	Held: Gaskins does not create an exception for White; statute of limitations bars relief
Whether the purported change in law would affect conviction validity	Gaskins would render the vehicle search (and consequent home seizure) unlawful, voiding evidence and undermining the conviction	The automobile exception remained controlling law; White did not dispute applicability of that exception	Held: White failed to show the new law would affect validity of his conviction
Whether a genuineness of material fact exists about Gaskins’ applicability	Gaskins concurrence suggests broader application; creates factual dispute	White never identified a factual dispute about applicability of the automobile exception	Held: No genuine issue of material fact; summary judgment appropriate
Whether lower courts must follow a concurrence as binding precedent	White relies on concurring opinion implication	Courts follow controlling majority precedent, not a concurrence	Held: Concurrence does not overrule or expand controlling precedent; not a basis to avoid limitations

State v. Gaskins, 866 N.W.2d 1 (Iowa 2015) (reinterpreting search-incident-to-arrest doctrine under Iowa Constitution)
Nguyen v. State, 829 N.W.2d 183 (Iowa 2013) (new constitutional rule may excuse PCR statute of limitations where prior precedent made claim futile)
Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (standard of appellate review for PCR legal issues)
State v. Edman, 444 N.W.2d 103 (Iowa Ct. App. 1989) (new-law exception requires showing the change would affect conviction validity)
State v. Beck, 854 N.W.2d 56 (Iowa Ct. App. 2014) (appellate courts must follow controlling supreme court precedent)