Jacob Lee Schmidt, Appellant v. State of Iowa, Appellee.

Summary

The court held that a knowing and voluntary guilty plea does not bar a freestanding actual-innocence claim under the Iowa Constitution when the claim relies on evidence extrinsic to the plea. It adopted a clear-and-convincing-evidence standard requiring proof that, considering all the evidence, no reasonable fact finder could convict the applicant. The court also held the recantation avoided the postconviction limitations period and remanded for the district court to apply the new standard through further summary proceedings. Justice Waterman and Justice Mansfield, dissenting, would have enforced the finality of the guilty plea and affirmed summary judgment.