Appeal from the Iowa District Court for Davis County,
Daniel P. Wilson, Judge. The State appeals the district court's ruling that the
defendant is a wrongfully imprisoned person under Iowa Code section 663A.1.
Thomas J. Miller, Attorney General, and William A. Hill, Assistant Attorney General, for appellant.
Steven P. Wandro, Kara M. Simons, and Shayla L. McCormally of Wandro & Associates, P.C., Des Moines, for appellee.
HECHT, Justice. All justices concur except Appel, J., who takes no part.
Patrick Nicoletto, a former high school basketball coach, was convicted of sexual exploitation by a school employee in violation of Iowa Code section 709.15(3) (2011). Immediately following his sentencing hearing, Nicoletto filed a notice of appeal, posted an appeal bond, and was released from custody. He did not spend any time inside a state penitentiary. On appeal, we determined a person holding only a coaching authorization was not subject to prosecution under the statute in force at the time, and we therefore reversed Nicoletto's conviction. State v. Nicoletto, 845 N.W.2d 421, 432 (Iowa 2014), superseded by statute, 2014 Iowa Acts ch. 1114, § 1 (codified at Iowa Code § 709.15(1)( f ) (2015)). After reversal of his conviction, Nicoletto filed an application requesting the district court enter an order finding Nicoletto is a " wrongfully imprisoned person" who is entitled to compensation from the State under Iowa Code section 663A.1 (2013). The district court granted Nicoletto's application. In this appeal, we determine whether defendants who fail to prove they were incarcerated in a prison can nonetheless be " imprisoned" within the meaning of section 663A.1.
I. Background Facts and Proceedings.
On July 20, 2012, Nicoletto was convicted of sexual exploitation of a student. See Iowa Code § 709.15(3) (2011). On October 3, the district court sentenced Nicoletto to an indeterminate prison term of five years and set a $7500 appeal bond. Within hours of his sentencing, Nicoletto posted the appeal bond and was released from custody, never spending a night incarcerated. On April 11, 2014, we reversed his conviction, finding that " a mere holder of a coaching authorization without a professional license . . . does not fall under the sexual exploitation statute." Nicoletto, 845 N.W.2d at 422. We remanded the case to the district court with instructions to dismiss the charges against Nicoletto. Id. at 432.
On May 7, Nicoletto filed an application seeking the district court's determination that he is a " wrongfully imprisoned person." See Iowa Code § 663A.1(1) (2013). The State filed a motion to dismiss, asserting Nicoletto's release on appeal bond precluded recovery under chapter 663A because it meant he was never imprisoned. The court found Nicoletto is a wrongfully imprisoned person under Iowa Code section 663A.1. The State appealed, and we retained the appeal.
II. Scope of Review.
We review a district court's ruling on wrongful imprisonment claims for correction of errors at law. State v. McCoy, 742 N.W.2d 593, 596 (Iowa 2007). We will uphold the district court's findings if substantial evidence supports them. Smith v. State, 845 N.W.2d 51, 54 (Iowa 2014). " We consider evidence substantial if a reasonable person would accept the evidence as adequate to reach the district court's conclusion." State v. Dohlman, 725 N.W.2d 428, 430 (Iowa 2006).
III. The Parties' Positions.
A. The State.
The State asserts that to qualify as a wrongfully
under section 663A.1, an individual must have been imprisoned in a state penitentiary (as opposed to a county jail) for some identifiable period of time. According to the State, the term " imprisoned," as used in the statute, is unambiguous and requires that a defendant actually spend time in a prison. The State distinguishes wrongful conviction, which it concedes may ...