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Keywords

defendantappealtrialtestimonymateriality

statuteappealtrialtestimonymotiondue processstatute of limitations

Related Cases

Harrington v. State, 659 N.W.2d 509

Facts

Terry Harrington was convicted of first-degree murder in 1978 for the shooting death of John Schweer, primarily based on the testimony of a juvenile accomplice, Kevin Hughes. After years of unsuccessful appeals and postconviction relief actions, Harrington filed a second postconviction relief application in 2000, claiming newly discovered evidence, including recantations from key witnesses and police reports implicating another suspect, Charles Gates. The district court denied his application, asserting it was time-barred and that the new evidence would not have changed the trial's outcome.

On August 4, 1978, Terry Harrington was convicted of first-degree murder in the shooting death of John Schweer. Harrington was charged with Schweer's murder and was ultimately convicted, primarily on the testimony of a juvenile accomplice, Kevin Hughes.

Issue

Did the district court err in denying Harrington's application for postconviction relief on the grounds that it was time-barred and that the newly discovered evidence would not have changed the outcome of the trial?

Did the district court err in holding Harrington's claims were time barred.

Rule

Under Iowa Code § 822.3, a postconviction relief application must be filed within three years of the final conviction unless a ground of fact or law that could not have been raised earlier is presented. Additionally, a Brady violation occurs when the prosecution suppresses evidence favorable to the defendant that is material to the issue of guilt.

Iowa Code § 822.3 (1999) (imposing a three-year statute of limitations on postconviction relief actions).

Analysis

The Supreme Court of Iowa found that Harrington's application was not time-barred because he presented a relevant ground of fact that could not have been raised earlier. The court also determined that the undisclosed police reports and witness recantations were material evidence that could have potentially changed the outcome of the trial. The court concluded that the prosecution's failure to disclose this evidence constituted a Brady violation.

Upon our review of the record and the arguments of the parties, we conclude (1) Harrington's appeal is timely; (2) this action is not time barred; (3) Harrington is entitled to relief on the basis of a due process violation; and (4) Harrington's motion for conditional remand is moot.

Conclusion

The Supreme Court reversed the district court's judgment and remanded the case for entry of an order vacating Harrington's conviction and granting him a new trial.

Accordingly, we reverse the district court judgment, and remand for entry of an order vacating Harrington's conviction and sentence, and granting him a new trial.

Who won?

Terry Harrington prevailed in the case because the Supreme Court found that the district court erred in its ruling regarding the timeliness of his application and the materiality of the newly discovered evidence.

Terry Harrington appeals a district court decision denying his application for postconviction relief. He claims the court erred in holding his claims were time barred.

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