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Iowa Supreme Court Rules District Courts Have Authority to Hear Postconviction Relief Actions Involving Deprivation of Liberty or Property Interest

by David Reutter

The Supreme Court of Iowa held that a motion for postconviction relief is the proper vehicle to challenge a substantial deprivation of liberty or property interest in certain Iowa Department of Corrections (“IDOC”) administrative actions.

In 1990, Kevin Franklin pleaded guilty to second-degree murder and second-degree sexual abuse for which he received 50 and 25 years, respectively. He has been eligible for parole since 2012.

Franklin filed a postconviction relief motion alleging he was unlawfully held in custody or other restraint — language consistent with Iowa Code § 822.2 (1)(e). He also filed a motion to correct an illegal sentence. In both motions, Franklin alleged that the IDOC required him to complete Sex Offender Treatment Program (“SOTP”) yet continually denied his request to participate. The IDOC practice of withholding SOTP until an offender is within three years of discharge artificially lengthened his sentence and effectively removed any meaningful chance of parole or work release. The parole board would not consider any relief until the completion of SOTP.

The district court combined both of these motions into one postconviction motion, and the State moved for summary judgment, arguing that this was better characterized as a parole or administrative issue.

The district court granted the motion for summary judgment, holding it lacked subject matter jurisdiction. The court noted that previous holdings showed that Chapter 822.2 claims were for disciplinary actions. Since Franklin’s case was not a disciplinary action, he was lawfully held in custody under his sentence. As his sentence was not illegal, he must pursue other remedies to challenge the policy, but the court failed to identify what those other remedies were.

The Iowa Supreme Court first distinguished the difference between subject matter jurisdiction and having the authority to hear the case. The former being the power to deal with a particular class of cases, and the latter having a legal standing to rule in a particular case. The Court clarified that it was not deciding Franklin’s claim, “but determining whether the [district] court can hear his claim as alleged.”

The Court stated that it reviews appeals of postconviction proceedings for errors of law. Summary judgments are granted only if there is no genuine issue as to any material fact, and the moving party is entitled to judgment as a matter of law. Both parties agreed that there were no disputed facts, so the only issue to decide was whether the district court had authority to adjudicate Franklin’s claim under § 822.2.

In accordance with the Pettit v. Iowa Department of Corrections, 891 N.W.2d (Iowa 2017), Maghee v. State, 773 N.W.2d 228 (Iowa 2009), Davis v. State, 345 N.W.2d 97 (Iowa 1984), line of cases, review of postconviction relief has been expanded to SOTP classifications, work-release revocations, and disciplinary actions involving a substantial deprivation of liberty or property interest. Franklin’s claim was that the IDOC’s policy of withholding SOTP until three years of one’s discharge date is effectively imposing a silent mandatory minimum, constituting a substantial deprivation of liberty interest.

The Supreme Court of Iowa ruled that Franklin has the right to pursue his claim under § 822.2(1)(e). As such, the Court reversed the district court order finding that it lacked subject matter jurisdiction to hear his case. The Court explained that this “is not a case concerning subject matter jurisdiction. Rather, it involves authority to hear the case.” Finally, the Court ruled that the district court had authority to hear this case.

Accordingly, the Court remanded the case for further proceedings consistent with this opinion. See: Franklin v. State, 905 N.W.2d 170 (Iowa 2017). 

 

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Franklin v. State




 

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