Posted on: May 21st, 2018


Following a plea of guilty and sentence, Jacob Lee Schimdt filed an application for postconviction-relief, claiming he was actually innocent although he knowingly and voluntarily pled guilty to the charged crimes.  As a result of a recantation by the victim, Schmidt claims actual-innocence.  The Iowa Supreme Court took up the issue.

Prior to this decision, the Iowa Supreme Court held that a plea of guilty prevented a defendant from later challenging the validity of that plea on all but the voluntary and intelligent nature of the plea.  Now, the Iowa Supreme Court held that 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.  The Court reasoned that, in certain circumstances, innocent people will plead guilty in exchange for reduced charges and shorter sentences.  The Court further stated that because the Iowa Code allows exoneration based on DNA evidence, there should be no distinction with that exception and exoneration based on other reliable evidence.

The Court held that the Iowa Constitution affords greater individual rights than does the United States Constitution.  The Court held that Article I, section 9 of the Iowa constitution provided an avenue for defendants who prove they are factually innocent to challenge these convictions.  The Court also held that Article I, section 17’s prohibition on cruel and unusual punishment was also implicated when actually innocent defendants are incarcerated.

The Court held that for an applicant to succeed on a freestanding actual-innocence claim, the applicant must show by clear and convincing evidence that, despite the evidence of guilt supporting the conviction, no reasonable fact finder could convict the applicant of the crimes for which the sentencing court found the applicant guilty in light of all the evidence, including the newly discovered evidence.  Finally, the Court held that the Iowa Constitution provides a floor to bring freestanding claims of actual innocence under the postconviction-relief statute, specifically sections 822.2(1)(a) and (d).

Schmidt v. State, No. 15-1408, 2018 WL 1440111, at *1 (Iowa Mar. 23, 2018)

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