Supreme Court of Iowa
Phuoc Nguyen, Appellant v. State of Iowa, Appellee
March 11, 20162016 Iowa Sup. LEXIS 31
Summary
The court affirmed the denial of Nguyen's postconviction-relief application. It held that postconviction counsel were not ineffective for failing to pursue a common-law retroactivity argument because the argument had already been considered and rejected when the court limited the retroactive application of the merger rule. The court also held that prospective application of that rule did not violate state due process, separation of powers, or state or federal equal protection guarantees.