When he was 16 years-old, James Steven Corder (defendant) killed his stepmother and burned down the family home. Corder was tried as an adult and convicted of first-degree murder and second-degree arson after a juvenile court granted the State’s motion to waive exclusive jurisdiction. In making the probable cause determination to waive jurisdiction required by Iowa Code § 232.45, the juvenile court relied upon a probable cause determination made in a previous detention order. Corder appealed the criminal court convictions, arguing that the juvenile court erred in waiving jurisdiction because it found probable cause on the basis of the State’s complaint and affidavit, without hearing testimony from any witnesses. The Iowa Court of Appeals affirmed the convictions. Corder then filed a petition for a writ of habeas corpus in federal district court. The district court denied the writ and Corder appealed.