The Iowa Supreme Court has issued a split opinion saying a man who plead guilty can have his case reviewed after the victim changed his story.
Jacob Lee Schmidt of Sioux City pleaded guilty to incest and assault with intent to commit sexual abuse on a younger relative back in 2007. He asked to have his conviction vacated after the victim recanted what he had earlier said about the abuse. The Woodbury County District court and Iowa Court of Appeals turned down his request.
The Iowa Supreme Court ruling says Schmidt’s case should get another look. It says sometimes an innocent person is choosing the lesser of two evils by pleading guilty despite their actual innocence because the odds are stacked up against them, or going to trial they risk losing and getting a harsher sentence. “Simply put, in economic terms, defendants engage in a cost-benefit analysis. Entering into a plea agreement is not only rational but also more attractive than dealing with the uncertainty of the trial process and the possibility of harsher sentences.”
The ruling says the legislature has set the policy that the state should not incarcerate actually innocent people if DNA evidence exonerates them, regardless of their pleas. “We see no reason why we should treat people exonerated by DNA evidence differently from people exonerated by other reliable means. For example, when the court determines the police planted evidence, such as drugs, why should that defendant remain in prison simply because he or she pled guilty to a reduced charge in light of the overwhelming evidence of his or her guilt? What kind of system of justice do we have if we permit actually innocent people to remain in prison?”
In its first ruling on the subject, the court says 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 ruling also waived the three-year statute of limitations on Schmidt’s appeal, saying the recantation was not available to Schmidt within the three-year period following the date of his conviction and “Schmidt could not have discovered the recantation earlier than he did in the exercise of due diligence.” The Supreme Court ordered the case sent back to the district court.
There were two dissenting opinions from justices Thomas Waterman, Edward Mansfield which justice Bruce Zager joining them. Waterman’s dissent says “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.’ ”
He writes that Schmidt closed the door to an appeal when he pleaded guilty in court and admitted what he had done. “The majority today errs by relying on cases in which the defendant steadfastly maintained his or her innocence through trial and all subsequent appeals.”
Waterman also raised concern about the statutue of limitations. “The majority undermines the finality of guilty pleas and eviscerates the three-year statute of limitations for postconviction-relief actions. Today’s decision will have bad consequences, as counsel for the State warned, including fewer plea bargains, renewed turmoil for victims and their families years after the crime, and a flood of PCR applications. The majority, by remanding this case instead of itself applying its new standard on the existing record, needlessly leaves district courts in the dark on whether evidentiary hearings or new trials will be required whenever a victim or other witness recants years after a defendant, ably represented by competent counsel, formally confessed to the crime in open court through a guilty plea devoid of legal error. Soon, we will see PCR applications by defendants who pled guilty to domestic assault and now bully the survivors into recanting. ”
Mansfield’s dissent was similar to Waterman’s.
Here’s the full ruling: Schmidt-Appeal-PDF