Schmidt v. State

The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and therefore, applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily.Appellant filed an application for postconviction relief under Iowa Code 822.2(1)(d), claiming that he was innocent and that he pled guilty because he was “scared.” The district court granted summary judgment for the State, concluding that Appellant waived his claim of actual innocence by pleading guilty. The Supreme Court reversed, holding (1) the Court hereby adopts a freestanding claim of actual innocence that applicants may bring under the postconviction relief statute; and (2) thus, Appellant’s pleas did not preclude him from filing a postconviction-relief action. View "Schmidt v. State" on Justia Law