Friday, March 23, 2018

Darwin In Iowa

A divided Iowa Supreme Court has held that a defendant who entered a knowing guilty plea can claim actual innocence

we overrule our cases holding that defendants may only attack the intrinsic nature—the voluntary and intelligent character—of their pleas. We now hold the Iowa Constitution allows freestanding claims of actual innocence, so applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily. Accordingly, we adopt a freestanding claim of actual innocence that applicants may bring under our post conviction relief statute.  Therefore, we vacate the decision of the court of appeals, reverse the judgment of the district court, and remand the case to the district court for further consideration consistent with this opinion.

The plea

On April 2, 2007, Schmidt entered into a plea agreement. He agreed to plead guilty to assault with intent to commit sexual abuse, an aggravated misdemeanor in violation of Iowa Code section 709.11 (amended count I) and incest (count IV).

Chief Justice Cady concurred in Justice Wiggins' majority opinion

The process of justice must always be fair. This case stands tall as the embodiment of this fundamental principle of law. It is a substantial step forward in our constitutional march to become better. Innocent people should always have a forum to prove their innocence. I fully concur in the opinion of the court.

Yet, the actual process of justice available to Schmidt to now pursue the new claim given to him must also be fair. This fairness is the reason the case must be remanded to the district court for it to decide if summary adjudication should be granted. I write separately only to explain this important part of the case more fully and why the actual innocence claim cannot now be decided on appeal.

Going forward, when an actual-innocence claim based on the recantation of a witness is brought in our courts, summary judgment will remain a viable procedural vehicle for the state to ask the court to resolve the claim. Consistent with all summary judgment proceedings, the legal issue will be whether the moving party is entitled to summary judgment, under a set of facts assumed to be undisputed for the purposes of the motion, because a reasonable juror could still conclude the defendant is guilty of the crime. For purposes of summary adjudication of witness recantation claims, the undisputed facts needed to support the motion will normally center on the remaining evidence of guilt from other witnesses found in the minutes of testimony. In many cases, the remaining evidence may support summary judgment, as a reasonable juror could still convict the defendant based on the surviving evidence...

The case needs to be remanded to the district court so the State can amend its motion for summary judgment to claim Schmidt has failed to bring a claim of actual innocence that survives summary adjudication. The district court needs to consider the motion after Schmidt has filed an amended response. This procedure is required to ensure the process of justice is fair.

Justice Waterman dissented

I respectfully dissent and would affirm the district court’s summary judgment and the court of appeals decision affirming it under our long-standing precedent enforcing the legal effect of guilty pleas. I join Justice Mansfield’s separate dissent. This year, the United States Supreme Court resoundingly reiterated a fundamental legal tenet: a valid guilty plea waives the defendant’s constitutional right to trial and right to confront witnesses and “relinquishes any claim that would contradict the ‘admissions necessarily made upon entry of a voluntary plea of guilty.’ ” Class v. United States, 583 U.S. ___, ___, 138 S. Ct. 798, 805 (2018) (quoting United States v. Broce, 488 U.S. 563, 573–74, 109 S. Ct. 757, 764 (1989)). A guilty plea precludes a defendant from a later challenge in which he would “deny that he engaged in the conduct to which he admitted.” Id. All nine justices agreed with that proposition.

Dissent also from Justice Mansfield

I respectfully dissent. Constitutional interpretation is not Darwinian evolution, and a decision of this court today is not superior to the decisions that preceded it just because it is more recent. Whether this court is on a “constitutional march to become better” should be determined by others, not by ourselves.

While it is tempting to agree that “[i]nnocent people should always have a forum to prove their innocence,” the realities of any criminal justice system are more complex. Even the majority does not take this statement literally. For example, even the majority accepts for now the limits in Iowa Code chapter 822 on claims brought by those who say they are actually innocent.

I join Justice Waterman’s dissent, and write separately only to highlight several points.

First, this case does not involve an actual recantation.

Second, the rule that a guilty plea waives all defenses and objections which are not intrinsic to the plea is both long-standing and sound.

Third, the court has provided no doctrinal basis for grounding an actual-innocence claim in the Iowa Constitution.

Fourth, the court leaves many questions unanswered that will have to be sorted out by our district judges in the coming years...

 From the State’s perspective, I am guessing it would have simply preferred to try Schmidt all those years ago. In the long run, I am doubtful today’s decision will benefit defendants. More importantly, today’s decision needlessly overturns an established rule of law that was fair to all parties and worked well.

Excellent recent updates to the Iowa Supreme Court web page provides access to the briefs and oral arguments. (Mike Frisch)

https://lawprofessors.typepad.com/legal_profession/2018/03/the-iowa-supreme-court-we-overrule-our-cases-holding-that-defendants-may-only-attack-the-intrinsic-naturethe-voluntary-an.html

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