Zane Jack Fields v. State, 314 P.3d 587

Fields was sentenced to death for first‑degree murder in 1991.
In 2011, Fields filed his sixth post‑conviction petition raising innocence, prosecutorial misconduct, and Sixth/ Fourteenth Amendment claims.
Gilcrist recanted his testimony in 2011, leading to Fields’ renewed claims and supporting affidavits.
The State moved to dismiss, challenging timeliness, materiality under oath, and whether the claims were merely impeaching.
The district court dismissed on all three grounds (untimeliness, lack of admissible material facts, and impeachment).
The Idaho Supreme Court affirmed the district court’s dismissal, applying the UPCPA/IC 19‑2719(5) standards for capital cases.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness under I.C. 19‑2719(5)	Fields argues timely under recantation date.	State argues timeliness is measured by knowledge reasonably known, not recantation date.	Timeliness upheld; petition untimely under knowability standard.
Material facts under I.C. 19‑2719(5)(a)	Fields attached affidavits and documents to support new claims.	Affidavits are insufficient if not admissible evidence with first‑hand facts.	Dismissal affirmed; petition lacked admissible material facts.
Impeaching or cumulative evidence under I.C. 19‑2719(5)(b)	Claims based on recantation and witness impeachment.	Declarations primarily impeachment and do not undermine reliability of conviction.	Dismissal affirmed; claims were merely impeaching.

Pizzuto v. State, 149 Idaho 155 (2010) (UPCPA timeliness; heightened burden for successive petitions)
Pizzuto v. State, 146 Idaho 720 (2008) (extraordinary circumstances for timeliness; admissible evidence rule)
Dunlap v. State, 141 Idaho 50 (2004) (strict waiver of timely claims; timeliness standard)
Payne v. State, 146 Idaho 548 (2008) (capital postconviction pleading requirements; admissible evidence)
Fields v. State, 154 Idaho 347 (2013) (recantation/malice issues in Fields proceedings)