from the Iowa District Court for Scott County, Stuart P.
defendant appeals from the district court's denial of his
motion in arrest of judgment.
C. Smith, State Appellate Defender, and Maria L. Ruhtenberg,
Assistant Appellate Defender, for appellant.
J. Miller, Attorney General, and Martha E. Trout, Assistant
Attorney General, for appellee.
Considered by Vogel, P.J., and Doyle and McDonald, JJ.
Roelandt appeals his convictions following his guilty pleas
to theft in the first degree, in violation of Iowa Code
sections 714.2(1), 902.8, and 902.9 (2015), and assault while
participating in a felony, in violation of Iowa Code section
708.3(2). Roelandt claims the district court erred in denying
his motion in arrest of judgment based on his assertion that
the State withheld exculpatory evidence.
Background Facts and Proceedings
March 30, 2016, the State charged Roelandt with one count of
robbery in the first degree and one count of possession of a
firearm as a felon as a habitual offender. On June 27, the
State amended the trial information to add one count of theft
in the first degree and one count of assault while
participating in a felony. In conjunction with a plea
agreement, Roelandt agreed to plead guilty to the
theft-in-the-first-degree count and the
assault-while-participating-in-a-felony count; in exchange,
the State agreed to dismiss the robbery and
the plea was accepted by the district court, Roelandt filed a
motion in arrest of judgment seeking to set aside his guilty
pleas based on his allegation the State had withheld
exculpatory information from him. Specifically, Roelandt
alleged the victim spoke to the county attorney on the
morning of Roelandt's guilty plea hearing and told the
county attorney that he could not state that Roelandt was the
perpetrator. The county attorney did not disclose the
conversation to Roelandt. Roelandt argued the failure to
disclose the conversation violated his due process rights in
accordance with Brady v. Maryland, 373 U.S. 83, 87
(1963). The district court denied Roelandt's motion.
Scope and Standard of Review
we review district court rulings on motions in arrest of
judgment for abuse of discretion. State v. Smith,
753 N.W.2d 562, 564 (Iowa 2008). However, "[w]hen the
applicant's claims are of a constitutional nature, we
will conduct a de novo review." DeSimone v.
State, 803 N.W.2d 97, 102 (Iowa 2011).
Motion in Arrest of Judgment
asserts the district court erred in denying his motion in
arrest of judgment because the victim's statement to the
prosecutor qualifies as Brady material and the
failure of the prosecutor to disclose it to Roelandt violated
his due process ...