State of Iowa v. Joshua Kelly Uranga, 950 N.W.2d 239

Joshua Uranga, a tier‑III registered sex offender (Iowa), was required to verify in person four times per year; he missed November 2016 and appeared December 7, 2016.
The State charged Uranga with first‑offense failure to comply with the sex‑offender registry.
At trial Uranga testified he had previously received form "flyer" letters from the sheriff when tardy and believed a December letter left at his grandmother’s house gave him five business days after November to appear.
After conviction, new counsel located a December 2, 2016 sheriff’s letter stating Uranga was noncompliant and would be charged if he did not appear within five business days of receipt; defense argued the letter constituted newly discovered evidence and/or a promise of leniency.
The district court denied the new‑trial motion; the court of appeals affirmed. The Iowa Supreme Court affirmed, holding Uranga had not shown the letter could not have been discovered with reasonable diligence because the letter was in discovery made available to prior defense counsel before trial and Uranga had actual notice of the letter.

Issue	State's Argument	Uranga's Argument	Held
Whether the December 2 letter was "newly discovered evidence" warranting a new trial	Letter was in the electronic discovery file provided to defense counsel before trial; not newly discovered	Letter was discovered after verdict by new counsel; it showed a sheriff’s promise/waiver and was material	Letter was not newly discovered; it was available pretrial and Uranga failed to show due diligence, so no new trial granted
Whether Uranga exercised reasonable diligence in discovering the letter	Defense (and defendant) had access to the file earlier; counsel’s failure to review does not excuse lack of diligence	Counsel turnover and Uranga’s fugitive status prevented earlier discovery; new counsel did not know discovery existed	Failure of trial counsel to obtain or review discovery is not a basis to treat material as newly discovered; due‑diligence requirement not met
Whether promise‑of‑leniency theory (and related jury instruction) warranted relief	Instruction was a legal question not properly raised pretrial; even if relevant, letter was not newly discovered	Uranga sought instruction and relied on the letter to show authorization to delay reporting	District court properly denied instruction and, because letter was not newly discovered, denial of new trial was not an abuse of discretion

State v. Smith, 573 N.W.2d 14 (Iowa 1997) (standards for new trial based on newly discovered evidence)
State v. Jefferson, 545 N.W.2d 248 (Iowa 1996) (evidence known at trial but not pursued cannot be treated as newly discovered)
State v. Compiano, 154 N.W.2d 845 (Iowa 1967) (reasonable‑diligence requirement; exhaust probable sources)
State v. Miles, 490 N.W.2d 798 (Iowa 1992) (court’s broad discretion on new‑trial motions; many claims fail on diligence)
State v. Walker, 935 N.W.2d 874 (Iowa 2019) (abuse‑of‑discretion standard for reviewing new‑trial denials)