Background
Robert Arthur Reynolds was convicted of second-degree murder for fatally shooting a friend of his wife in 2014. The Iowa Court of Appeals affirmed his conviction in 2020, and procedendo issued on May 29, 2020.
In 2023, while in prison, Reynolds experienced temporary disorientation and confusion that a doctor attributed to a transient ischemic attack, or TIA. In October 2024, he sought postconviction relief, contending that the diagnosis was newly discovered evidence requiring a new trial. The district court granted the State summary disposition, finding the application untimely and the diagnosis not newly discovered evidence.
The Court’s Holding
The Iowa Court of Appeals affirmed. Iowa’s three-year postconviction-relief limitations period ran from the issuance of procedendo, and Reynolds did not establish the statutory exception for a ground of fact that could not have been raised earlier.
Although Reynolds received the TIA diagnosis after the limitations period, the record showed that he knew or should have known of materially similar symptoms before trial. He told the 911 operator after the shooting that he did not know what happened, appeared blank or emotionless afterward, and family affidavits described similar episodes dating to childhood. Those facts put him on inquiry notice to investigate potential neurological issues. The same lack of due diligence also defeated his alternative newly-discovered-evidence claim.
Key Takeaways
- A later medical diagnosis does not necessarily create a new factual ground for postconviction relief when the applicant knew of the underlying symptoms before the limitations period expired.
- The ground-of-fact exception requires no prior opportunity to raise the claim; inquiry notice arises when known information would prompt a reasonable person to investigate.
- Because Reynolds could have discovered the asserted condition through due diligence before trial, his newly-discovered-evidence claim also failed.
Why It Matters
The decision underscores that Iowa postconviction applicants cannot rely on the date of a new diagnosis alone to avoid the three-year filing deadline. Courts will examine whether known symptoms or other circumstances previously alerted the applicant to a potential claim.