Brandon Daniel Ruiz v. State of Iowa

Summary

The court affirmed dismissal of Ruiz's second postconviction-relief application as untimely. It declined to consider his equitable-tolling argument because he failed to preserve it, and it rejected his claim that appointed counsel's inaction constituted structural error because the record did not establish constructive denial of counsel or identify a nonmeritorious argument that could have avoided dismissal. The court also declined to remand for development of the ineffective-assistance claim because Ruiz did not specify how competent representation probably would have changed the outcome.