Tammy Smith v. State of Iowa, 2014 Iowa Sup. LEXIS 37

Tammy Smith was convicted in 2007 of child endangerment resulting in serious injury of her four-year-old son and sentenced to an indeterminate term not to exceed ten years.
The Court of Appeals affirmed the conviction; postconviction relief produced evidence suggesting the injury may have occurred differently, and on remand the district court vacated the conviction and dismissed the case.
Smith filed a wrongful imprisonment action under Iowa Code section 663A.1 in 2011 alleging she was wrongfully imprisoned.
The district court found insufficient clear and convincing evidence that she or anyone else did not commit the crime.
The Court of Appeals affirmed; the Supreme Court granted further review to determine whether substantial evidence supports the district court’s findings.
The Supreme Court affirmed, holding there was substantial evidence that the offense was not proven not to have been committed by anyone.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Smith qualifies as a wrongfully imprisoned person under 663A.1(1)	Smith contends she meets all criteria under 663A.1(1) due to vacated conviction and imprisonment.	State argues Smith must also prove no one committed the offense under 663A.1(2).	No; eligibility requires additional clear and convincing proof under 663A.1(2).
Whether clear and convincing evidence shows no one, including Smith, committed the offense	Smith can show no person committed the offense by clear and convincing evidence, via new evidence about the injury.	State contends substantial evidence does not support that no one committed the offense.	Substantial evidence supports that the offense was not shown to have been not committed by any person.
Whether the district court's factual findings are supported by substantial evidence	Smith argues the new and existing records show no doubt the crime was not committed by anyone.	State asserts the record leaves substantial doubt that no one committed the crime.	Yes; the district court’s findings are supported by substantial evidence.

State v. Dohlman, 725 N.W.2d 428 (Iowa 2006) (defines substantial doubt standard for no-one-committed burden and explains application to 663A.1(2))
McCoy v. State, 742 N.W.2d 593 (Iowa 2007) (establishes burden on applicant to prove by clear and convincing evidence under 663A.1(2))
In re C.B., 611 N.W.2d 489 (Iowa 2000) (clarifies the meaning of the clear and convincing standard in this context)
State v. DeSimone, 839 N.W.2d 660 (Iowa 2013) (recognizes use of wrongful conviction records in 663A.1 proceedings)
State v. Dohlman, 725 N.W.2d 428 (Iowa 2006) (reiterates standard for reviewing wrongful imprisonment claims on correction of errors at law)