Guy Dell Sudduth v. State of Iowa

Summary

The Iowa Court of Appeals affirmed the summary disposition of Guy Dell Sudduth’s application for postconviction relief from 2005 convictions for criminal transmission of HIV. The court held that Rhoades v. State does not apply retroactively and that Sudduth’s actual-innocence claim, raised for the first time on appeal, was not preserved and was otherwise barred by the postconviction statute of limitations.

Holdings

1. Rhoades does not apply retroactively to individuals whose direct appeals were final before Rhoades was decided; therefore, Rhoades did not invalidate the factual basis for Sudduth's Alford pleas.
2. Sudduth's claim that his sentence was illegal because he was factually innocent was not preserved because it challenged the underlying conviction and was raised for the first time on appeal.
3. A free-standing actual-innocence claim is subject to the requirements of Iowa Code section 822.3, including its three-year limitation period.

Questions Presented

1. Whether Rhoades v. State, 848 N.W.2d 22 (Iowa 2014), applies retroactively to invalidate the factual basis for Sudduth's 2005 Alford pleas.
2. Whether Sudduth's actual-innocence claim, characterized as a challenge to an illegal sentence, was preserved for appellate review.
3. Whether a free-standing actual-innocence claim is subject to Iowa Code section 822.3's three-year PCR limitation period.

Disposition

affirmed