James Williams v. State of Iowa
CourtCourt of Appeals of Iowa
Date FiledJuly 22, 2026
Docket25-0816
StatusPublished
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Full Opinion
IN THE COURT OF APPEALS OF IOWA
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No. 25-0816
Filed July 22, 2026
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James Williams,
Applicant–Appellant,
v.
State of Iowa,
Respondent–Appellee.
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Appeal from the Iowa District Court for Black Hawk County,
The Honorable David F. Staudt, Judge.
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AFFIRMED
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Pamela Wingert of Wingert Law Office, Spirit Lake, attorney for appellant.
Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Schumacher, P.J., Buller, J., and Vogel, S.J.
Opinion by Schumacher, P.J.
1
SCHUMACHER, Presiding Judge.
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.
2