Norman Wayne Davis IV v. State of Iowa

Summary

The Iowa Supreme Court affirmed the district court’s dismissal of Norman Davis’s post‑conviction relief application, holding that under Iowa Code § 822.3 an application is not filed until it is received by the clerk of the district court. The Court declined to adopt the federal “prison‑mailbox” rule, finding the statutory text unambiguous and requiring filing with the clerk. The decision rests on a plain‑meaning textual analysis of the relevant statutes and rules.