State of Iowa v. William Cory Scott, 15-1836

In 1991 William Cory Scott (age 21) shot and killed Willie Guyton; convicted of first-degree murder under alternative theories: specific intent and felony murder (predicates: willful injury and terrorism). Sentenced to mandatory life without parole under Iowa law.
Trial jury instructed that conviction could rest on participation in willful injury or terrorism; Scott was convicted and direct appeal affirmed in 1993.
Scott pursued multiple postconviction challenges (ineffective assistance, improper instructions under Heemstra); prior collateral challenges were denied and appeals affirmed.
In 2015 Scott filed a motion to correct an illegal sentence arguing terrorism was not a proper predicate felony for felony murder; the district court summarily dismissed the motion and denied reconsideration.
Scott appealed; the State raised jurisdictional defenses (no appeal from denial of motion to correct illegal sentence; untimely notice), but the court proceeded to address the merits.
The court rejected Scott’s claims: (1) limitations on using willful injury and terrorism as predicate felonies are prospective only, and (2) Scott’s Eighth Amendment cruel-and-unusual-punishment challenge failed the gross-proportionality threshold.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to hear appeal from denial of motion to correct illegal sentence	State: No right to appeal; untimely notice	Scott: timely motion for reconsideration preserved rights	Court treated appeal as certiorari petition, addressed merits despite timing concerns; refusal to dismiss on jurisdictional grounds
Use of terrorism as felony-murder predicate	State: Terrorism was a valid predicate at time of trial; limitation in Nguyen is prospective	Scott: Terrorism is not a forcible felony and cannot support felony-murder under Heemstra reasoning	Court: Limitation on terrorism as predicate is prospective only (citing Nguyen); no illegal-sentence relief
Use of willful injury as felony-murder predicate	State: Willful injury valid at time; Heemstra applied prospectively	Scott: Heemstra forecloses willful injury as predicate and renders sentence illegal	Court: Willful injury limitation is prospective only (citing Goosman); prior challenges denied
Eighth Amendment cruel-and-unusual punishment (categorical or as-applied)	State: Life without parole not grossly disproportionate to intentional killing	Scott: Life without parole is cruel/unusual given circumstances	Court: No inference of gross disproportionality; sentence passes threshold for both categorical and as-applied challenges; claim rejected

State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (limits on predicate felonies in felony-murder context)
Goosman v. State, 764 N.W.2d 539 (Iowa 2009) (Heemstra limitation applied prospectively to willful injury)
Nguyen v. State, 878 N.W.2d 744 (Iowa 2016) (addressing terrorism as predicate felony; prospective application)
State v. Oliver, 812 N.W.2d 636 (Iowa 2012) (Eighth Amendment gross-proportionality framework)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (scope of review for illegal sentence and de novo review of constitutional issues)
State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (motion to correct illegal sentence not for relitigating trial errors)
State v. Fuhrmann, 261 N.W.2d 475 (Iowa 1978) (legislature’s authority to define crimes)
State v. Rhode, 503 N.W.2d 27 (Iowa Ct. App. 1993) (life imprisonment not grossly disproportionate for murder)

Writ denied.