Robert Arthur Reynolds, Applicant–Appellant, v. State of Iowa, Respondent–Appellee. (2026)

Robert Reynolds was convicted of second-degree murder after shooting and killing a friend of his wife on April 8, 2014. He appealed, and our court affirmed his conviction. State v. Reynolds, No. 18-0179, 2020 WL 1551135, at *5 (Iowa Ct. App. Apr. 1, 2020). Procedendo issued on May 29, 2020.

While serving his sentence in 2023, prison staff took Reynolds to receive medical care after he became extremely disoriented, confused, and upset. A doctor later determined that Reynolds's momentary disorientation and confusion resulted from a transient ischemic attack (TIA). Based on that diagnosis, Reynolds filed an application for postconviction relief (PCR) on October 14, 2024, claiming discovery of his TIA diagnosis was newly discovered evidence entitling him to a new trial.

The State filed a motion for summary disposition arguing Reynolds's PCR application was time-barred because it was filed outside the three-year limitation period set by Iowa Code section 822.3 (2024), and his medical condition was not newly discovered. The district court agreed and granted the State's motion. Reynolds appeals.

I. Standard of Review and Summary Disposition

We review PCR proceedings, including summary dispositions, for errors at law. Moon v. State, 911 N.W.2d 137, 142 (Iowa 2018). We apply summary judgment standards to summary dispositions in PCR actions. Id. Summary disposition is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show ․ there is no genuine issue as to any material fact and ․ the moving party is entitled to a judgment as a matter of law.” Id. (alterations in original) (quoting Iowa R. Civ. P. 1.981(3)). We view the record in the light most favorable to the nonmoving party, including all legitimate inferences that can be drawn from it. Id. This standard also applies to statute-of-limitations issues. Id. at 143.

II. Analysis

Reynolds claims the district court erred in granting summary disposition. He contends his TIA diagnosis was a ground of fact that could not have been discovered within the three-year period following issuance of procedendo after his direct appeal, so his claim meets an exception to the statute of limitations. See Iowa Code § 822.3. On the merits, he contends his TIA diagnosis constitutes newly discovered evidence entitling him to a new trial. See id. § 822.2(1)(d). We address each contention in turn.

A. Exception to the Statute of Limitations

Iowa Code section 822.3 requires a PCR application to “be filed within three years from the date of conviction ․ or, in the event of an appeal, from the date the writ of procedendo is issued” unless “a ground of fact or law that could not have been raised within the applicable time period” exists. Under the ground-of-fact exception upon which Reynolds relies, he must show (1) that he could not have raised the ground of fact alleged within the limitations period and (2) that a nexus between the ground of fact and the challenged conviction exists. Moon, 911 N.W.2d at 143.

Reynolds claims a genuine issue of material fact exists regarding whether he could have discovered the TIA diagnosis during the limitations period. He argues he had no way of knowing he had the condition nor the reasonable ability to relay his symptoms to a doctor within the applicable time period.

For the ground-of-fact exception to apply, the applicant must have had “no opportunity to assert the claim before the limitation period expired.” LeGear v. State, No. 19-0465, 2020 WL 5229176, at *5 (Iowa Ct. App. Sep. 2, 2020) (quoting Cornell v. State, 529 N.W.2d 606, 610 (Iowa Ct. App. 1994) (internal quotation marks omitted)). “[T]he focus of our inquiry [is] whether the applicant was or should have been ‘alerted’ to the potential claim before the limitation period expired.” Id. (citation omitted). When an applicant becomes aware of “information that would alert a reasonable person of the need to investigate,” the applicant has “inquiry notice of all facts that would have been disclosed by a reasonably diligent investigation.” Id. (quoting Skagburg v. Gately, 911 N.W.2d 786, 794 (Iowa 2018)). The applicant need not have “exact knowledge of the nature of the problem ․ because it is sufficient that the person be aware that a problem existed.” Id. (cleaned up).

In LeGear, our court addressed a similar claim to that being made by Reynolds. There, the PCR application was based in part on the applicant's new diagnosis of dissociative amnesia made after the limitations period for filing a PCR application expired. Id. But our court noted that, although the diagnosis was new, “the fact that LeGear suffered from symptoms of amnesia at the time of his criminal trial is not.” Id. The court stressed that the symptoms of amnesia were known at the time of the criminal trial, so it concluded that any defense derived from the new diagnosis was also available at that time. Id. Therefore, the court found the exception to the statute of limitations did not apply and the application was time barred. Id.

The PCR record here, including affidavits from Reynolds's family members, show that he knew or should have known “that a problem existed” prior to his criminal trial let alone before the PCR limitation period expired. See id. In the 911 call after the killing, Reynolds told the operator, “I don't even actually know what happened,” and he told an officer later that he didn't know why he was going to jail. Witnesses also testified that he looked emotionless, “blank,” or like “he was looking through [them] not at [them]” after the killing. The affidavits his siblings submitted in support of Reynolds's resistance to the State's motion for summary disposition describe witnessing Reynolds exhibiting similar behavior since childhood. One sibling's affidavit described confronting Reynolds about one such incident, but Reynolds had no memory of it. The similarity between his past symptoms and his condition at the time of the killing placed Reynolds on inquiry notice of potential neurological problems. See id.

Because Reynolds had knowledge at the time of his criminal trial that he suffered from the same symptoms around the time of that killing as the symptoms he displayed that led to his diagnosis of TIA years later, his diagnosis does not raise a ground of fact that could not have been pursued within the limitations period for PCR applications. See id. Reynolds did not carry his burden of showing that a genuine issue of material fact exists as to the first element of his ground-of-fact claim, so we need not address whether a nexus existed between the diagnosis and the crime. Thus, Reynolds failed to establish an exception to the statute of limitations, and we affirm the district court's dismissal of Reynold's PCR application as time barred.

B. Newly Discovered Evidence Under Section 822.2(1)(d)

Even if Reynolds's claim was not time barred, he cannot prevail on the merits of his claim for PCR. Under Iowa Code section 822.2(1)(d), an applicant can obtain PCR when “[t]here exists evidence of material facts, not previously presented and heard, that requires vacation of the conviction or sentence in the interest of justice.” An applicant claiming PCR based on newly discovered evidence must show by a preponderance of the evidence

(1) that the evidence was discovered after the verdict; (2) that it could not have been discovered earlier in the exercise of due diligence; (3) that the evidence is material to the issues in the case and not merely cumulative or impeaching; and (4) that the evidence probably would have changed the result of the trial.

Moon, 911 N.W.2d at 151 (citation omitted).

For the same reasons we rejected Reynolds's claim that the ground-of-fact exception to the statute of limitations applied, we reject Reynolds's claim that he is entitled to PCR based on newly discovered evidence. Assuming he had TIA at the time of the killing, as he now claims, Reynolds could have discovered that he had that condition prior to his criminal trial. As such, no genuine issue of material fact exists as to the second element of Reynolds's newly-discovered-evidence claim. Accordingly, we affirm the district court's dismissal of Reynolds's PCR application.

III. Conclusion

Because the symptoms of Reynolds's TIA were known to him at the time of his criminal trial, the ground-of-fact exception to the statute of limitations does not apply, so his PCR application is time barred. For the same reason, even if his claim was not time barred, his claim for PCR based on newly discovered evidence fails. Therefore, we affirm the district court's dismissal of Reynolds's PCR application via summary disposition.

AFFIRMED.

Opinion by Ahlers, J.