# Nick C. Rhoades v. State of Iowa

> Supreme Court of Iowa · April 15, 2016 · 880 N.W.2d 431

URL: https://www.frixlaw.com/law-library/cases/9822726

## Case

- **Full name:** Nick C. RHOADES, Appellant, v. STATE of Iowa, Appellee
- **Court:** Supreme Court of Iowa
- **Decided:** April 15, 2016
- **Citations:** 880 N.W.2d 431; 2016 Iowa Sup. LEXIS 47; 2016 WL 1533519
- **Precedential status:** Published
- **Opinion:** Concurrence by Zager
- **Judges:** Appel, Cady, Wiggins, Hecht, Waterman, Mansfield, Zager
- **Cited by:** 42 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9822726

## How later opinions describe it (automated extraction)

- 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

## Opinion text

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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9822726. Public record. Not legal advice.