Background
In 2017, a jury convicted Michael Lajeunesse of attempted murder and willful injury causing serious injury for beating and strangling a woman with whom he had a romantic relationship. The Iowa Court of Appeals affirmed the convictions on direct appeal, and procedendo issued in April 2018.
After unsuccessfully pursuing two postconviction-relief applications, Lajeunesse filed a third application in May 2022, alleging ineffective assistance of counsel and due-process violations. The State sought summary disposition under Iowa Code section 822.3, which generally requires a postconviction-relief application to be filed within three years after procedendo issues. The district court dismissed the application, finding that Lajeunesse had not shown a ground of fact or law that could not have been raised within the limitations period.
The Court’s Holding
The Iowa Court of Appeals affirmed. On appeal, Lajeunesse argued that the statutory ground-of-fact exception applied because circumstances beyond his control prevented him from presenting testimony from the victim’s treating physician within the three-year period.
The court held that Lajeunesse failed to preserve that argument because he did not raise it when resisting the State’s motion for summary disposition and the district court did not consider it. The court further concluded that, even if the issue had been preserved, Lajeunesse did not establish an exception to section 822.3’s three-year limitations period. His third postconviction-relief application was therefore time-barred.
Key Takeaways
- A postconviction applicant must ordinarily file within three years after procedendo issues following a direct appeal.
- An appellate argument invoking the ground-of-fact exception is not preserved when it was neither raised before nor decided by the district court.
- Lajeunesse did not establish that his proposed ground could not have been raised within the statutory period, so summary disposition was proper.
Why It Matters
The decision reinforces both the strict timing requirements governing Iowa postconviction proceedings and the need to present claimed statutory exceptions to the district court. An applicant cannot rely for the first time on appeal on an asserted ground of fact that was not raised in opposition to summary disposition.