Roland v. State of Iowa - Postconviction Relief Appeal

Iowa Court of Appeals

Filed April 1st, 2026

Detected April 1st, 2026

Summary

The Iowa Court of Appeals decided Case No. 24-1167, affirming in part and reversing in part the district court's denial of William Roland's postconviction relief application. The court affirmed the denial of Roland's ineffective-assistance-of-counsel claim but reversed the dismissal of his actual-innocence claim, remanding for further proceedings on that claim.

View original document View source feed page

What changed

The Iowa Court of Appeals affirmed the district court's denial of Roland's ineffective-assistance-of-counsel claim, agreeing he failed to prove counsel was deficient. However, the court reversed the district court's dismissal of Roland's actual-innocence claim. The lower court had held Roland was barred from raising actual innocence because he entered an Alford plea, but the appellate court found this rationale inconsistent with supreme court precedent recognizing actual-innocence claims even after guilty pleas. Since the State never argued the evidence failed to meet the actual-innocence standard and the district court never decided that merits issue, remand is required.

Criminal defendants and their counsel should note that actual-innocence claims remain viable even after Alford pleas, and courts cannot bar such claims solely based on the plea. The State must still challenge the merits of actual-innocence evidence if it wishes to seek affirmance on that alternative basis. No compliance deadlines apply to this appellate decision.

Source document (simplified)

Main Content

Case No. 24-1167

William Paul Roland

v.
State of Iowa

Appellant

William Paul Roland

Appellee

State of Iowa

Attorney for the Appellant

James S. Blackburn

Attorney for the Appellee

Adam Kenworthy, Assistant Attorney General

Court of Appeals

Court of Appeals Opinion

Opinion Number:

24-1167

Date Published:

Apr 01, 2026

Summary

Appeal from the Iowa District Court for Polk County, The Honorable Paul D. Scott, Judge. AFFIRMED IN PART, REVERSED IN PART, AND REMANDED. Considered without oral argument by Tabor, C.J., and Ahlers and Langholz, JJ. Buller, J., takes no part. Opinion by Langholz, J. (16 pages)

William Roland appeals the district court’s denial of his timely application for postconviction relief after a bench trial on that application. He argues that the court erred in: (1) finding that he failed to prove his ineffective-assistance-of-counsel claim and (2) holding that he was “barred from raising” his actual-innocence claim because he “entered into a plea agreement pursuant to Alford and has presented no new evidence that was unavailable during the initial proceedings.” OPINION HOLDS: On our de novo review, we agree with the district court’s finding that Roland failed to prove his ineffective-assistance-of-counsel claim. But we cannot square the court’s basis for barring Roland’s actual-innocence claim with the controlling supreme court precedent recognizing that claim even after a guilty plea. And the State has never argued—on appeal or in the district court—that the evidence Roland presented fails to meet the actual-innocence standard justifying either summary disposition or denial after trial. Nor did the district court decide that merits issue. So we cannot affirm on that potential alternative basis for resolving Roland’s claim. We thus affirm the district court’s denial of Roland’s ineffective-assistance-of-counsel claim, reverse its dismissal of his actual-innocence claim, and remand for further proceedings on the actual-innocence claim.