Bruns v. State

LAVORATO, Justice.

Iowa’s postconviction relief statute has two statutes of limitation: a ninety-day period for postconviction appeals involving a prison disciplinary decision and a three-year period for collaterally attacking criminal convictions. See Iowa Code § 663A.3 (1991). The applicant in this disciplinary proceeding claims the shorter period of limitations is constitutionally infirm because it violates his equal protection rights. He also claims that correctional officials violated his due process rights by not informing him that he had only ninety days to appeal the disciplinary…