Martin Shane Moon v. State of Iowa

WIGGINS, Justice.

An applicant filed a postconviction-relief action alleging the State committed a Brady 1 violation by withholding potentially exculpatory information regarding the statements made by a witness who ultimately did not testify at the applicant's criminal trial. The applicant further alleged this information constituted newly discovered evidence. The district court declined to reach the merits of the applicant's substantive claims. Rather, the court applied the newly-discovered-evidence test, instead of the new-ground-of-fact test, to hold that the three-year statute of…