finding that such an individual could not recover damages under Iowa Code chapter 663A for wrongful imprisonment
How later courts described this case
- finding that such an individual could not recover damages under Iowa Code chapter 663A for wrongful imprisonment
- holding guilty plea barred recovery for wrongful imprisonment
- stating that “we ordi narily assume when a legislature enacts statutes it - is aware of. the state of the law”
- explaining that relief under chapter 663A is not available to individuals who pleaded guilty
Written by the judges who cited it.
The opinion
ZAGER, Justice
(concurring specially).
I respectfully concur in the result only. I write separately because I would deny relief to Rhoades under the facts of his case. As I stated in my dissent in Rhoades v. State, the record, when viewed as a whole and allowing all reasonable inferences, provided an ample factual basis for his guilty plea. 848 N.W.2d 22, 39 (Iowa 2014) (Zager, J., dissenting). I found in that case that his guilty plea was valid, unaffected by any claim of ineffective assistance of counsel. Id. The wrongful imprisonment statute requires a finding that “[t]he individual did not plead guilty to the public offense charged.” Iowa Code § 663A.1(1)(&) (2015). Not only did Rhoades enter-a guilty plea, but his guilty plea was supported by a factual basis. He therefore fails to meet the threshold requirement of the statute. Rhoades’s valid entry of a factually sufficient guilty plea deprives him of the right to recover under the statute.