BOBBY RAY WOODBERRY v. STATE OF IOWA (2025)

Nearly thirty years ago, Bobby Woodberry was convicted of first-degree murder and assault with intent to commit serious bodily injury; he was sentenced to life in prison. Woodberry filed an unsuccessful direct appeal, on which procedendo issued in March 1997. Accordingly, his three-year window to seek postconviction relief (PCR) closed in 2000. See Iowa Code § 822.3 (2000). Yet Woodberry filed this PCR application—his sixth—in July 2023. The district court summarily dismissed it as time-barred.

Woodberry appeals, arguing New York State Rifle & Pistol Ass'n v. Bruen, 597 U.S. 1 (2022) is a new ground of law that he could not raise before, which excepts him from the statute of limitations in section 822.3. “But [Woodberry] is not challenging his conviction based on Bruen or any other new ground of fact or law. His arguments based on Bruen are only a challenge to the statute of limitations itself. So this exception to the statute of limitations does not apply to [Woodberry's] application.” Thongvanh v. State, No. 24-0783, 2025 WL 547744, at *1 (Iowa Ct. App. Feb. 19, 2025); Roach v. State, No. 24-0074, 2025 WL _____, at *_ (Iowa Ct. App. May 21, 2025) (same).

Alternatively, Woodberry urges us to overrule our supreme court's holding that the statute of limitations in section 822.3 is constitutional. See Davis v. State, 443 N.W.2d 707, 710–11 (Iowa 1989) (“[D]ue process requires that the interest of the state and the defendant be balanced in determining the reasonableness of a period of limitations․ We believe that a three-year period after the conviction or appeal is final is not unreasonable. We also believe the legislature, within its sound discretion, may determine the proper limitation period.”). We cannot overrule precedent from our supreme court. See State v. Beck, 854 N.W.2d 56, 64 (Iowa Ct. App. 2014).

We affirm the district court's dismissal of Woodberry's PCR application.

AFFIRMED.

POTTERFIELD, Senior Judge.