James Williams, Applicant–Appellant, v. State of Iowa, Respondent–Appellee. (2026)

In 2009, James Williams was convicted of two counts of first-degree robbery, assault while participating in a felony, and possession of a firearm. His convictions were affirmed on direct appeal. State v. Williams, No. 09-0155, 2010 WL 446532, at *2–6 (Iowa Ct. App. Feb. 10, 2010). Procedendo issued in 2010. Williams filed the instant postconviction-relief (PCR) application—his fifth—in 2024. The district court granted the State's motion to dismiss the application.

On appeal, Williams contends Iowa Code section 822.3 (2024) “is an unconstitutional limit on the right to habeas corpus.” Williams did not raise this claim before the PCR court, and therefore, it has not been preserved for our review. Love v. State, 543 N.W.2d 621, 624 (Iowa Ct. App. 1995). Notwithstanding, we observe that the crux of Williams's claim has been “repeatedly addressed and rejected” by this court. See Velazquez-Ramirez v. State, No. 24-0294, 2025 WL 2407963, at *1 (Iowa Ct. App. Aug. 20, 2025) (listing cases rejecting applicants’ claims that New York State Rifle and Pistol Ass'n v. Bruen, 597 U.S. 1 (2022), provides a new ground of law exempting PCR applications from section 822.3’s time bar). We further note that it is not the prerogative of this court to “revisit” Davis v. State, 443 N.W.2d 707 (Iowa 1989) “in light of Bruen,” as Williams requests. See State v. Beck, 854 N.W.2d 56, 64 (Iowa Ct. App. 2014) (noting the court of appeals is “not at liberty to overrule controlling supreme court precedent”).

We affirm the dismissal of Williams's fifth PCR application.

AFFIRMED.

Opinion by Schumacher, P.J.