Fernando Sandoval v. State of Iowa

CourtSupreme Court of Iowa
DecidedJune 10, 2022
Docket20-0396
StatusPublished

This text of Fernando Sandoval v. State of Iowa (Fernando Sandoval v. State of Iowa) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fernando Sandoval v. State of Iowa, (iowa 2022).

Opinion

IN THE SUPREME COURT OF IOWA

No. 20–0396

Submitted February 22, 2022—Filed June 10, 2022

FERNANDO SANDOVAL,

Appellant,

vs.

STATE OF IOWA,

Appellee.

Appeal from the Iowa District Court for Polk County, Joseph Seidlin,

Judge.

Appellant appeals from the dismissal of his application for postconviction

relief as barred by the statute of limitations and challenges the constitutionality

of his sentence to life imprisonment. AFFIRMED.

McDonald, J., delivered the opinion of the court, in which Christensen,

C.J., and Waterman, Mansfield, Oxley, and McDermott, JJ., joined. Appel, J.,

filed an opinion concurring in part and dissenting in part.

Jessica Maffitt of Benzoni Law Office, P.L.C., Des Moines, for appellant.

Thomas J. Miller, Attorney General, and Kyle Hanson, Assistant Attorney 2

General, for appellee. 3

McDONALD, Justice.

In February 2005, Fernando Sandoval was convicted of two counts of

first-degree murder and two counts of attempted murder. He was sentenced to

serve concurrent terms of life imprisonment without the possibility of parole for

the murder convictions and twenty-five years’ imprisonment for the attempted

murder convictions. Sandoval unsuccessfully challenged his convictions on

direct appeal and in three different applications for postconviction relief. This

appeal arises out of the dismissal of Sandoval’s fourth application for

postconviction relief, which the district court held was barred by the three-year

statute of limitations set forth in Iowa Code section 822.3 (2019). Sandoval

contends the district court erred in dismissing his fourth application for

postconviction relief. He also asserts a new claim on appeal. He contends that

because he was only nineteen at the time he murdered two people, his mandatory

life sentences without the possibility of parole violate the federal and state

constitutional prohibitions against “cruel and unusual punishment.” U.S. Const.

amend. VIII; Iowa Const. art. I, § 17.

I.

Generally, an application for postconviction relief “must be filed within

three years from the date the conviction or decision is final or, in the event of an

appeal, from the date the writ of procedendo is issued.” Iowa Code § 822.3. In

Allison v. State, this court held that a second application for postconviction relief

filed beyond the three-year-limitations period would relate back to the filing of

the first application and be considered timely if three conditions were met: (1) the 4

first application was timely filed; (2) the second application alleged prior

postconviction counsel provided ineffective assistance in presenting the first

application; and (3) the second application was “filed promptly after the

conclusion of the first [postconviction relief] action.” 914 N.W.2d 866, 891 (Iowa

2018). Subsequently, the general assembly amended section 822.3 and

abrogated Allison. 2019 Iowa Acts ch. 140, § 34 (codified at Iowa Code § 822.3

(2020)). Effective July 1, 2019, section 822.3 provides that “[a]n allegation of

ineffective assistance of counsel in a prior case under this chapter shall not toll

or extend the limitation periods in this section nor shall such claim relate back

to a prior filing to avoid the application of the limitation periods.” Id.

Sandoval has repeatedly challenged his convictions since 2005. He

pursued a direct appeal after being sentenced, and the court of appeals affirmed

his convictions. State v. Sandoval, No. 05–0426, 2006 WL 3018152, at *6 (Iowa

Ct. App. Oct. 25, 2006). Procedendo issued on November 21, 2006. Sandoval

filed his first application for postconviction relief in June 2007. The application

was dismissed on the merits in December 2008, and this court dismissed the

appeal as frivolous. Sandoval filed two additional applications for postconviction

relief in May 2012 and January 2016, both of which were dismissed as

time-barred. The court of appeals affirmed both dismissals. See Sandoval v.

State, No. 16–1875, 2018 WL 2727690, at *2 (Iowa Ct. App. June 6, 2018);

Sandoval v. State, No. 14–0341, 2015 WL 1849404, at *2 (Iowa Ct. App. Apr. 22,

2015). And in April 2015, Sandoval filed a motion for new trial in the underlying

criminal case, which was denied. 5

At issue in this case is Sandoval’s fourth application for postconviction

relief. Sandoval filed the application on July 8, 2019, after the effective date of

the amendments to Iowa Code section 822.3. In his application, Sandoval alleged

his trial counsel provided ineffective assistance in failing to investigate the

qualifications of Sandoval’s translator at trial, in failing to investigate the case,

and in failing to challenge questionable jury instructions. He further alleged that

his appellate counsel and first postconviction counsel provided ineffective

assistance in failing to raise these claims. The district court dismissed the

application as time-barred pursuant to section 822.3. The district court rejected

the contention that Allison provided Sandoval with relief. The district court

concluded that the amendment to section 822.3 abrogated Allison. In addition,

the district court concluded that Allison was not applicable because the

application for postconviction relief was Sandoval’s fourth, not his second, and

because Sandoval did not promptly file his fourth application after the

conclusion of the first postconviction relief action. Finally, the district court

rejected Sandoval’s contention that new evidence excused the otherwise

untimely application.

The district court did not err in concluding Sandoval’s fourth application

for postconviction relief was barred by the statute of limitations. With respect to

Sandoval’s direct appeal, procedendo issued on November 21, 2006. Sandoval’s

fourth application, filed in July 2019, is outside the three-year statute of

limitations. And Allison does not provide Sandoval with any relief. As the district

court correctly explained, Allison was abrogated by the amendment to 6

section 822.3, effective July 1, 2019, and Sandoval filed his application on

July 8.

Sandoval contends the amendment abrogating Allison is not applicable

here because he mailed his fourth application for postconviction relief on

June 27, 2019, prior to the effective date of the amendment. Sandoval asserts

that under the “prison mailbox rule,” his application should be deemed filed on

the date he placed the application in the prison mail system. See, e.g., Moore v.

United States, 173 F.3d 1131, 1135 (8th Cir. 1999) (stating a filing “is deemed

timely filed when an inmate deposits the notice in the prison mail system prior

to the expiration of the filing deadline”). Iowa has not adopted the prison mailbox

rule, and we need not decide whether to do so here.

Even if Sandoval’s fourth application should be deemed filed on the date

he placed it in the prison mail system, Allison would still not provide him with

any relief. Allison held only that a second application for postconviction relief

could relate back to a timely filed first application.

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