Ruthann Veal v. State of Iowa

Summary

The Iowa Supreme Court held that a challenge to a juvenile offender’s mandatory life-without-parole sentence on cruel-and-unusual-punishment grounds constitutes a challenge to an illegal sentence. Because illegal-sentence challenges may be raised at any time under Iowa Rule of Criminal Procedure 2.24(5)(a), the court held that Iowa’s postconviction-relief statute of limitations did not apply, vacated the court of appeals’ decision, reversed the district court, and remanded.

Holdings

1. A challenge to a sentence under the Cruel and Unusual Punishment Clauses of the United States and Iowa Constitutions is a challenge to an illegal sentence because it alleges that the sentencing court lacked the power to impose the sentence.
2. The three-year limitations period governing ordinary postconviction relief actions does not apply to a challenge alleging that a sentence is illegal.
3. Veal's application must be treated as a challenge to an illegal sentence not subject to the three-year limitations period, and the case must proceed in the district court.

Questions Presented

1. Whether a constitutional challenge to a sentence as cruel and unusual punishment constitutes a challenge to an illegal sentence under Iowa Rule of Criminal Procedure 2.24(5)(a).
2. Whether the three-year limitations period in Iowa Code section 822.3 applies to a challenge alleging that the sentence is illegal.
3. Whether Veal's application should be treated on remand as an illegal-sentence challenge rather than as an ordinary time-barred postconviction relief action.

Disposition

reversed_and_remanded