Sammy Lemorris Clayton, Applicant-Appellant v. State of Iowa
15-1826
| Iowa Ct. App. | Nov 9, 2016Background
- In January 2006 Sammy Clayton pleaded guilty to second-degree murder and received a 50-year sentence.
- More than eight years later Clayton filed a postconviction-relief (PCR) application claiming ineffective assistance of counsel, including failure to advise him of a diminished-capacity defense and canceling a scheduled diminished-capacity exam before the plea.
- The State moved to dismiss the PCR application as time-barred under Iowa Code § 822.3 (three-year limitation from final conviction).
- The district court dismissed the application as untimely; Clayton appealed, focusing on one claim (counsel failed to advise about diminished capacity and the canceled exam) and arguing it fit a statutory exception to the limitations period.
- The appellate court reviewed legal error de novo and evaluated whether Clayton’s claim fit the “ground of fact” or “ground of law” exceptions to the statute of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Clayton’s claim that counsel failed to advise him about diminished capacity and a canceled exam qualifies as a "ground of fact" that could not have been raised within 3 years | Clayton: facts (counsel’s failure to advise and canceled exam) were unknown to him and thus a ground of fact outside the limitations period | State: those facts were known or discoverable at plea time; client is charged with attorney’s knowledge; thus not a ground of fact | Court: Rejected plaintiff; facts were known or discoverable and thus not an exception |
| Whether Castro v. State created a change in law that would excuse filing beyond three years (a "ground of law") | Clayton: Castro’s disavowal of Speed constitutes a change in law that could not have been timely raised | State: Even if Castro changed law, Clayton failed to file within three years of that decision; claim still time-barred | Court: Rejected plaintiff; either Castro is not a qualifying change in law or claim was not filed within three years of Castro |
| Whether the State’s motion for summary disposition was procedurally defective (untimely) | Clayton: State’s motion was untimely | State: Motion filed within statutory time and applicable extensions | Court: Rejected plaintiff; motion timely under section 822.6 and extensions |
| Whether the State’s motion lacked required supporting documents (statement of undisputed facts & memorandum) | Clayton: Motion unsupported and procedurally improper | State: No statutory requirement for the specific support; no prejudice to Clayton | Court: Rejected plaintiff; no required form and no prejudice; claims barred on the merits |
Key Cases Cited
- Castro v. State, 795 N.W.2d 789 (Iowa 2011) (addressed standards for ineffective-assistance claims and timeliness issues)
- Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (explained "ground of fact" exception requirements)
- State v. Straw, 709 N.W.2d 128 (Iowa 2006) (held facts must be material to decision to plead guilty to qualify under exceptions)
- Carroll v. Martir, 610 N.W.2d 850 (Iowa 2000) (attorney's knowledge imputed to client)
- State v. Edman, 444 N.W.2d 103 (Iowa Ct. App. 1989) (described change-in-law requirement for "ground of law" exception)
- Speed v. State, 616 N.W.2d 158 (Iowa 2000) (case discussed in relation to Castro and change-in-law arguments)
- Smith v. State, 882 N.W.2d 126 (Iowa Ct. App. 2016) (collecting decisions holding claims time-barred when not filed within three years of the asserted change in law)