Michael Alexander Lajeunesse v. State of Iowa

── Michael Alexander Lajeunesse v. State of Iowa ── Court: Court of Appeals of Iowa Date: April 15, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 25-0507 Filed April 15, 2026 _______________ Michael Alexander Lajeunesse, Applicant–Appellant, v. State of Iowa, Respondent–Appellee. _______________ Appeal from the Iowa District Court for Polk County, The Honorable Jeffrey Farrell, Judge. _______________ AFFIRMED _______________ Michael A. Lajeunesse, Anamosa, self-represented appellant. Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney General, attorneys for appellee. _______________ Considered without oral argument by Greer, P.J., Chicchelly, J., and Doyle, S.J. Opinion by Chicchelly, J. 1 CHICCHELLY, Judge. Michael Lajeunesse appeals from the order dismissing his postconviction-relief (PCR) action for lack of prosecution.1 He contends that the district court erred by requiring him to prepay filing fees under Iowa Code chapter 610 (2024). He also contends that the court did not serve him with a copy of the order stating its deadline for service and intent to dismiss the case for lack of prosecution, preventing him from requesting more time to satisfy service requirements. Finding no error, we affirm. BACKGROUND FACTS AND PROCEEDINGS Lajeunesse is incarcerated on convictions for attempted murder and willful injury causing serious injury. This court affirmed the convictions on direct appeal and preserved his claims of ineffective assistance of counsel for PCR proceedings. See State v. LaJeunesse, No. 17-0507, 2018 WL 1099024, at *4–6 (Iowa Ct. App. Feb. 21, 2018). 2 Lajeunesse has brought three unsuccessful PCR actions, two of which this court affirmed on appeal. See Lajeunesse v. State, No. 21-0817, 2022 WL 1654831 (Iowa Ct. App. May 25, 2022); Lajeunesse v. State, No. 19-1715, 2022 WL 469408 (Iowa Ct. App. Feb. 16, 2022). In November 2024, Lajeunesse filed this action, asking that the court vacate the prior PCR rulings and allow him to bring the ineffective-assistance 1 Although Lajeunesse captioned this action as a “Petition for Declaratory Judgment,” the supreme court found that it “is more properly considered a petition for [PCR] because that is the exclusive means to challenge a conviction.” So we refer to the underlying action as a PCR action while mindful that it was not docketed or treated as such below. 2 Because there is a discrepancy in the capitalization of his last name, we conform to the style used in the appellant’s brief. 2 claims preserved on direct appeal for adjudication on the merits. At the same time, Lajeunesse moved “to proceed without prepaying the filing fee” due to his indigency. Because Lajeunesse is incarcerated, the court ordered that he pay twenty percent of the filing fee and make monthly payments of ten percent of the outstanding balance. See Iowa Code § 610A.1(1)(a). It denied his motion to reconsider the ruling.3 In February 2025, the court issued an order warning Lajeunesse that unless he filed proof of service or moved for an extension within twenty-eight days, it would dismiss the action. When neither occurred within the deadline, the court dismissed the action without prejudice and taxed costs to Lajeunesse. Lajeunesse petitioned the Iowa Supreme Court for a writ of certiorari. Because the order dismissing the action was final, the supreme court treated the petition for writ of certiorari as a notice of appeal. It also deferred payment of the filing fee until final disposition, “a