Supreme Court of Iowa

Deandre D. Goode, Appellant v. State of Iowa, Appellee.

November 16, 2018920 N.W.2d 520

Summary

The court held that a claim alleging ineffective assistance of postconviction counsel, raised for the first time on appeal and unsupported by an adequate record, cannot be remanded to the postconviction court for development. The claim must instead be brought in a separate postconviction-relief application, although the statutory limitation period does not bar a promptly filed successive application under the applicable relation-back rule. The court vacated the court of appeals decision and affirmed the district court judgment.