The U.S. Court of Appeals for the Third Circuit recently cited a 2008 Iowa Law Review article, “The Innocent Prisoner’s Dilemma: Consequences of Failing to Admit Guilt at Parole Hearings,” written by Daniel Medwed, a professor of law at the University of Utah S.J. Quinney College of Law, in a case involving a challenge to the Pennsylvania parole process. That article argues that innocent prisoners often face a classic Catch-22 when appearing before parole boards: either maintain innocence and decrease their chance of gaining parole or admit “guilt” to boost the odds of a favorable parole grant while simultaneously harming future efforts to prove their innocence through litigation. Although the Third Circuit found no constitutional violation in the inmate’s particular case, it cited Professor Medwed’s work for the proposition that “The statute can present a potential for disadvantage, however, if it is applied with the admission of guilt requirement, which carries the specter of collateral consequences.” Medwed’s research on this topic was also featured in a recent New York Times article and on-line video.