Rhoades v. State

Appellant pleaded guilty to one count of criminal transmission of HIV. Appellant later filed an application for postconviction relief alleging that his trial counsel provided ineffective assistance by allowing Appellant to plead guilty to a charge for which there was no factual basis. The lower courts denied relief, but the Supreme Court reversed and remanded the case. On remand, the State dismissed the charges against Appellant. Appellant then filed an action under Iowa Code 663A claiming that he was wrongfully imprisoned by the State and was entitled to compensation. The district court granted the State’s motion to dismiss, concluding that Appellant was not entitled to relief because he had pled guilty in a criminal case that provided the basis for the imprisonment. The Supreme Court affirmed, holding that section 663A.1(1)(b) categorically excludes all persons who plead guilty from Iowa’s wrongful imprisonment statute, and therefore, Appellant was not entitled to pursue a claim for wrongful imprisonment under section 663A. View "Rhoades v. State" on Justia Law