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Ruthann Veal Vs. State Of Iowa
Citation: Not availableDocket: 08–1207
Court: Supreme Court of Iowa; February 25, 2010; Iowa; State Supreme Court
Original Court Document: View Document
Ruthann Veal appealed the dismissal of her postconviction relief application challenging her life imprisonment without the possibility of parole (LWOP) sentence for first-degree murder, arguing it constituted cruel and unusual punishment due to her status as a juvenile at the time of the offense. The Iowa District Court had ruled her claim was barred by the three-year statute of limitations for postconviction relief, a decision upheld by the Iowa Court of Appeals. Veal contended that her claim was timely due to a change in law following the U.S. Supreme Court decision in Roper v. Simmons, which prohibited the death penalty for offenders under eighteen. The district court disagreed, asserting that Roper did not apply to LWOP sentences. The Supreme Court of Iowa vacated the Court of Appeals' decision, reversed the district court's ruling, and remanded the case for further proceedings, indicating potential legal errors in the lower courts' determinations. The district court's jurisdiction to hear Veal's claim is evaluated in light of the Iowa Supreme Court's decision in State v. Bruegger, which established that a cruel-and-unusual-punishment challenge constitutes an assertion of an "illegal sentence" under Iowa Rule of Criminal Procedure 2.24(5)(a). This rule allows for correction of illegal sentences at any time, which means that the time limitations of the postconviction relief statute, Iowa Code section 822.3, do not apply to illegal sentence claims. The State acknowledged that if Veal's claim is viewed as an illegal sentence challenge, the statutory time restrictions would not be applicable. The court agrees with both the State's concession and existing case law, asserting that claims of illegal sentences challenge the court's authority to impose a sentence rather than merely its legal validity. Therefore, Veal's claim is not regarded as a postconviction relief action and is not subject to the statute of limitations. Consequently, the district court's dismissal of Veal's cruel-and-unusual-punishment claim is reversed, and the case is remanded for further proceedings, with directions to treat the application as a challenge to an illegal sentence. All justices concur except Justice Baker, who abstained from participation.