Edwards inquiry (Iowa) · Go Syfert
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Edwards inquiry in Iowa

5 Iowa opinions name it 2 courts 2003–2021 1 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
State v. Kinkeadgreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2021–2021
1 sentence

2021In conducting a de novo review, “we may consider evidence presented at the suppression hearing as well as evidence presented at trial.” State v. Kinkead, 570 N.W.2d 97, 99 (Iowa 1997). 3 smell [marijuana].” He requested consent to search, which Edwards granted, and he found drug paraphernalia and vape pens that tested positive for marijuana compounds.

11
Illinois v. Allengreen
scotus · 1970 · cited in 1 Iowa opinions naming this issue, 2020–2020
2 sentences

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

11
State of Iowa v. Ken Lorenze Kuhsegreen
iowa · 2020 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020See State v. Kuhse, 937 N.W.2d 622 , 627 (Iowa 2020).1 We generally preserve such claims for postconviction proceedings unless we find a satisfactory record to review.

11
Faretta v. Californiagreen
scotus · 1975 · cited in 1 Iowa opinions naming this issue, 2020–2020
2 sentences

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

11
State v. Newsomgreen
iowa · 1987 · cited in 1 Iowa opinions naming this issue, 2003–2003
2 sentences

2003Holding that it did, the court reasoned as follows: Just as written waivers are insufficient to justify police-initiated interrogation after the request for counsel in a Fifth Amendment analysis, so too they are insufficient to justify police-initiated interrogations after the request for counsel in a Sixth Amendment analysis. [[Image here]] We thus hold that, if police initiate interrogation after a defendant’s assertion, at an arraignment or similar proceeding, of his right to counsel, any waiver of the defendant’s right to counsel for that police-initiated interrogation is invalid. 475 U.S.

2003Holding that it did, the court reasoned as follows: Just as written waivers are insufficient to justify police-initiated interrogation after the request for counsel in a Fifth Amendment analysis, so too they are insufficient to justify police-initiated interrogations after the request for counsel in a Sixth Amendment analysis. [[Image here]] We thus hold that, if police initiate interrogation after a defendant’s assertion, at an arraignment or similar proceeding, of his right to counsel, any waiver of the defendant’s right to counsel for that police-initiated interrogation is invalid. 475 U.S.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Indiana v. Edwards green
scotus · 2008
2 sentences

2020“Rather, the determination of [the defendant’s] competence or lack thereof must be predicated solely on his ability to ‘carry out the basic tasks needed to present his own defense without the help of counsel’; notwithstanding any mental incapacity or impairment serious enough to call that ability into question.” Jason, 779 N.W.2d at 76 n.2 (quoting Edwards, 554 U.S. at 175–76).

2020“Rather, the determination of [the defendant’s] competence or lack thereof must be predicated solely on his ability to ‘carry out the basic tasks needed to present his own defense without the help of counsel’; notwithstanding any mental incapacity or impairment serious enough to call that ability into question.” Jason, 779 N.W.2d at 76 n.2 (quoting Edwards, 554 U.S. at 175–76).

12020–2020
State v. Jason green
iowactapp · 2009
2 sentences

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

2020For the purpose of the Edwards inquiry, “the issue to be decided . . . is not whether the defendant lacked the technical legal skill or knowledge to conduct the trial proceedings effectively without counsel.” Jason, 779 N.W.2d at 76 n.2 (citation omitted); see also Faretta, 422 U.S. at 834 (“[A]lthough [the defendant] may conduct his own defense ultimately to his own detriment, his choice must be honored out of ‘that respect for the individual which is the lifeblood of the law.’” (quoting Illinois v. Allen, 397 U.S. 337 , 350–51 (1970) 13 (Brennan, J., concurring))).

12020–2020
Maryland v. Shatzer green
scotus · 2010
2 sentences

2010Maryland v. Shatzer, — U.S.-, -, 130 S.Ct. 1213, 1227 , - L.Ed.3d -,-(2010).

2010Maryland v. Shatzer, — U.S.-, -, 130 S.Ct. 1213, 1227 , - L.Ed.3d -,-(2010).

12010–2010

Where else courts name it

TX 92 (1986–2026) CA 78 (1981–2026) IL 57 (1980–2024) VA 52 (1986–2026) PA 36 (1986–2026) GA 31 (1986–2026) WI 30 (1973–2025) OH 26 (1988–2026) MS 25 (1992–2024) AL 21 (1980–2015) DC 20 (1977–2023) LA 19 (1982–2026) FL 18 (1981–2026) CO 18 (1989–2026) TN 17 (1985–2021) MI 17 (1983–2026) KS 17 (1994–2020) WA 15 (1982–2025) MN 13 (1989–2015) MO 13 (1912–2016) IN 12 (1987–2018) NJ 12 (1986–2025) AZ 10 (1977–2022) MD 10 (1993–2013) DE 10 (1986–2017) OR 9 (1986–2025) SC 9 (1978–2016) MA 8 (1991–2014) OK 8 (1974–2008) AK 8 (1983–2019) NC 7 (1985–2018) KY 6 (1973–2021) CT 6 (1991–2022) AR 6 (1988–2001) NE 5 (2016–2025) NV 5 (1985–2013) IA 5 (2003–2021) NY 5 (1979–2018) WY 4 (1991–2011) SD 4 (1990–2019) ME 4 (1990–2012) WV 4 (1995–2013) UT 4 (1984–2023) VT 3 (1986–1999) ID 3 (1982–2011) NM 3 (2012–2016) MT 3 (2009–2011) HI 2 (1983–2014) NH 2 (1983–2003) RI 2 (2002–2004)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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