Background

• Patrick Nicoletto, a high-school coach, was convicted under Iowa Code § 709.15(3) and sentenced to an indeterminate five-year prison term on October 3, 2012. He posted an appeal bond the same day and was released; he never served time in a state penitentiary.
• On appeal the Iowa Supreme Court reversed his conviction, holding the statute did not apply to a mere holder of a coaching authorization. State v. Nicoletto, 845 N.W.2d 421 (Iowa 2014).
• Nicoletto then sought a district-court declaration that he was a “wrongfully imprisoned person” under Iowa Code § 663A.1 and thus eligible to pursue compensation; the district court granted relief.
• The State appealed, arguing § 663A.1 requires actual imprisonment in a state prison (not brief county-jail custody or mere restraint) and that Nicoletto never served time in prison.
• The Iowa Supreme Court reviewed statutory language, statutory scheme distinguishing jail and prison, and analogous statutes from other states, and concluded Nicoletto failed to prove he was “imprisoned” under § 663A.1 because he never served time in a state prison. The court reversed the district court.

Issues

Key Cases Cited

• State v. Nicoletto, 845 N.W.2d 421 (Iowa 2014) (reversal of conviction because statute did not apply to coaching authorization holders)
• Smith v. State, 845 N.W.2d 51 (Iowa 2014) (standards for reviewing wrongful-imprisonment claims under chapter 663A)
• Cox v. State, 686 N.W.2d 209 (Iowa 2004) (identifying the five statutory criteria defining a “wrongfully imprisoned person”)
• State v. Allensworth, 823 N.W.2d 411 (Iowa 2012) (discussing statutory interpretation principles and distinctions between custodial statuses)