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State of Iowa
State of Iowa
Attorneys for Appellant
Christopher A. Clausen
Attorneys for Appellee
Kyle Hanson, Assistant Attorney General
Court of Appeals
Court of Appeals Opinion
Appeal from the Iowa District Court for Story County, Timothy J. Finn, Judge. REVERSED AND REMANDED. Considered by Vaitheswaran, P.J., and Doyle and Bower, JJ. Opinion by Doyle, J. (9 pages)
Atiba Spellman appeals the order dismissing his action for postconviction relief (PCR) as a discovery sanction. OPINION HOLDS: The reasoning supporting dismissal of Spellman’s PCR action is flawed. First, the PCR court overlooked that Spellman amended his PCR application to provide the desired specificity for his PCR claims before the hearing on discovery sanctions. Second, we disagree that Spellman’s failure to provide discovery answers impeded the State’s ability to move for summary judgment. Third, Spellman did provide interrogatory answers within the deadline set forth in the court’s order compelling him to answer, and it is more likely that his failure to provide more specific answers or documents results from inability rather than willful refusal. Finally, the circumstances here are less egregious than in cases where the courts upheld dismissal as a discovery sanction. Given these circumstances, we find the PCR court abused its discretion in dismissing Spellman’s PCR application as a discovery sanction. For these reasons, we reverse and remand for further proceedings.