July 25, 2016
An eventual exoneration through DNA and related evidence does not give a defendant the right to seek damages in Iowa if he or she originally entered a guilty plea in the case. The decision by the Iowa Supreme Court, with potential implications for California, will not consider possible coercion in a confession or threats of a lengthy sentence upon a defendant, which could further affect the handling of the case.
Justice Brent Appel determined that the law providing compensation for victims of wrongful imprisonment excludes anyone who originally signed a guilty plea agreement, no matter the outcome of the case. For example, a person who was originally charged with murder but who agrees to a lesser charge, such as manslaughter, would not qualify for the compensation, even if DNA evidence later exonerates the person. However, he further noted that the legislature could update the laws, which could later change the ruling.
The specific case involved Nick Rhoades, 41, who spent nearly 12 months in custody after he entered a guilty plea to criminal transmission of HIV in 2009. His conviction was later vacated by the state supreme court after his legal team convinced the judge that the laws regarding transmission of the virus were outdated and not in keeping with current medical information on infection with the disease.
The defendant filed a civil lawsuit for wrongful imprisonment, but a judge dismissed the case because of the plea agreement that he signed. His lawyer unconvincingly countered that the new insight on the laws negated his guilty plea and further requested that the court vacate the plea.
Like several other states, including California, Iowa enacted wrongful imprisonment rights for exonerated prisoners. Ohio and other states with similar legislation also prevent people who have signed plea agreements from seeking financial compensation. The Innocence Project hopes to reverse these laws in efforts to provide someone who has plead guilty the opportunity to seek remuneration.
Changes in laws or new evidence via DNA samples might mean the reversal of a conviction. Wrongfully imprisoned defendants might then seek financial compensation. If you have questions about a wrongful conviction, talk with our office for further assistance.
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