Legal Opinion

Jacob Lee Schmidt v. State of Iowa

Supreme Court of Iowa

Decided March 23, 2018No. 15-1408PublishedCited by 218 opinions

1Opinion of the Court

WIGGINS, Justice.

*781An applicant filed a postconviction-relief action claiming he was actually innocent although he knowingly and voluntarily pled guilty to the charged crimes. He based his actual-innocence claim on a recantation by the victim. The district court granted the State's motion for summary dismissal/summary judgment, ruling the applicant cannot use the recantation to attack his knowing and voluntary guilty pleas because the recantation was extrinsic to the pleas. The applicant appealed, and we transferred the case to our court of appeals. The court of appeals affirmed. The applicant…

2Cases cited63 opinions

  1. Schlup v. DeloSupreme Court of the United States · 1995
  2. Murray v. CarrierSupreme Court of the United States · 1986
  3. McMann v. RichardsonSupreme Court of the United States · 1970
  4. Engle v. IsaacSupreme Court of the United States · 1982
  5. McCleskey v. ZantSupreme Court of the United States · 1991

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3Cited by218 opinions

  1. Martin Shane Moon v. State of IowaSupreme Court of Iowa · 2018
  2. State of Iowa v. Scottize Danyelle BrownSupreme Court of Iowa · 2019
  3. Cathryn Ann Linn v. State of IowaSupreme Court of Iowa · 2019
  4. People v. ReedIllinois Supreme Court · 2020
  5. People v. TigerNew York Court of Appeals · 2018

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