1. Iowa Code § 914.7 (2025) entitled "Rights not restorable" infringes the Petitioner's right to keep and bear arms enshrined by the Second and Fourteenth Amendments—suspended upon Mr. Browne's 1991 convictions under Iowa law for Willful Injury, a forcible felony, and Criminal Gang Participation—sentences he fully discharged nearly twenty-eight years ago (January 16th, 1998), paid all restitution, fines, or other financial obligations for, and for which he has had his other lost citizenship rights restored for over twenty years—by barring him from having that right restored for life.

2. The Iowa Constitution vests clemency authority in the Governor "subject to such regulations as may be provided by law." Iowa Const. Art. IV, § 16. Unlike the U.S. Constitution, that text explicitly authorizes legislative regulation of clemency powers in Iowa. Iowa Const. Art. III, § 1 permits such regulation where "expressly directed or permitted." Read together, these provisions allow the Iowa General Assembly to regulate clemency's effects—a principle given effect by § 914.7.

3. The contrary Iowa constitutional and statutory construction reached by the panel below was not merely legally erroneous, but profoundly so. The holding in Slater v. Olson, 299 N.W. 879 at 881 (Iowa 1941) only addressed the recognition of "other collateral consequences" flowing from a pardon; it did not consider, nor purport to decide, whether the Iowa General Assembly could curtail the Governor's clemency authority to restore such rights in the first instance, as § 914.7 expressly does.

4. Thus, under Iowa law, the Petitioner cannot have his right to keep and bear arms restored for life, even by a gubernatorial pardon.

Whether a state law permanently barring firearm rights restoration for individuals with prior forcible felony convictions violates the Second and Fourteenth Amendments, even after full sentence completion and gubernatorial pardon