predecessor rule (Iowa) · Go Syfert
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predecessor rule in Iowa

27 Iowa opinions name it 2 courts 1979–2026 8 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 (18)

CaseFollowedCited
Committee on Professional Ethics & Conduct of the Iowa State Bar Ass'n v. Baudinogreen
iowa · 1990 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015See Comm. on Prof'l Ethics & Conduct v. Baudino, 452 N.W.2d 455, 458 (Iowa 1990) (interpreting DR 1-102(A)(4), the predecessor to rule 32:8.4(c)). *561 In regards to the execution of a will, the Iowa Code provides: All wills and codicils, except as provided in section 633.283, to be valid, must be in writing, signed by the testator, or by some person in the testator’s presence and by the testator’s express direction writing the testator’s name thereto, and declared by the testator to be the testator’s will, and witnessed, at the testator’s request, by two competent persons who signed as witnes

2015See Comm. on Prof’l Ethics & Conduct v. Baudino, 452 N.W.2d 455, 458 (Iowa 1990) (interpreting DR 1–102(A)(4), the predecessor to rule 32:8.4(c)). 10 In regards to the execution of a will, the Iowa Code provides: All wills and codicils, except as provided in section 633.283, to be valid, must be in writing, signed by the testator, or by some person in the testator’s presence and by the testator’s express direction writing the testator’s name thereto, and declared by the testator to be the testator’s will, and witnessed, at the testator’s request, by two competent persons who signed as witnesse

22
Committee on Professional Ethics & Conduct of the Iowa State Bar Ass'n v. Mollmangreen
iowa · 1992 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015See Comm. on Prof'l Ethics & Conduct v. Mollman, 488 N.W.2d 168, 171 (Iowa 1992) (interpreting DR 1-102(A)(4), the predecessor to rule 32:8.4(c)).

2015See Comm. on Prof’l Ethics & Conduct v. Mollman, 488 N.W.2d 168, 171 (Iowa 1992) (interpreting DR 1–102(A)(4), the predecessor to rule 32:8.4(c)).

22
Holmes v. Polk City Savings Bankgreen
iowa · 1979 · cited in 2 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Bank, 278 N.W.2d 32, 35 (Iowa 1979) (rejecting a petition to vacate as untimely under the predecessor to rule 1.1013).

2014Bank, 278 N.W.2d 32, 35 (Iowa 1979) (rejecting a petition to vacate as untimely under the predecessor to rule 1.1013).

22
Terry Christiansen v. Iowa Board of Educational Examinersgreen
iowa · 2013 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026Exam’rs, 831 N.W.2d 179, 191 (Iowa 2013); Reyes v. Int’l Van Lines, Inc., 9 N.W.3d 793 , 801 (Iowa Ct. App. 2024); cf. Erickson, 485 N.W.2d at 85 (relying on rule 89—which was the predecessor of rule 1.402(5)—but finding amended petition did not relate back).

11
Erickson v. Wright Welding Supply, Inc.green
iowa · 1992 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026Exam’rs, 831 N.W.2d 179, 191 (Iowa 2013); Reyes v. Int’l Van Lines, Inc., 9 N.W.3d 793 , 801 (Iowa Ct. App. 2024); cf. Erickson, 485 N.W.2d at 85 (relying on rule 89—which was the predecessor of rule 1.402(5)—but finding amended petition did not relate back).

11
Blake James Jacobs v. Iowa Department of Transportation, Motor Vehicle Divisiongreen
iowa · 2016 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026Another example is our rules of electronic filing, whose promulgation was legislatively authorized in Iowa Code section 602.1614, and which we have read to “allow[] a corrected filing to relate back to the date of [a timely filed] original submission.” Jacobs v. Iowa Dep’t of Transp., 887 N.W.2d 590, 599 (Iowa 2016); see also Toney v. Parker, 958 N.W.2d 16 202, 209 (Iowa 2021) (discussing the rules of electronic filing and applying the Jacobs relation-back framework).

11
In the Interest of T.V.green
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025See In re T.V., 563 N.W.2d 612, 614 (Iowa 1997) (applying the predecessor to rule 6.806).

11
Stoner v. Kilengreen
iowactapp · 1995 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See In re Moser, No. 12–0762, 2012 WL 5954180 , at *1–2 (Iowa Ct. App. Nov. 29, 2012); In re Marriage of Woldegabir, No. 13-0765, 2014 WL 2348255 , at *5 (Iowa Ct. App May 29, 2014); cf. Stoner v. Kilen, 528 N.W.2d 648, 650 (Iowa Ct. App. 1995) (affirming denial based on the predecessor to rule 1.1013’s discovery requirement in the context of a default judgment).

11
State v. Beavergreen
iowactapp · 1988 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See State v. Beaver, 429 N.W.2d 778, 779 (Iowa Ct. App. 1988) (“[R]ule 6(6) [(the predecessor to rule 2.6(6))] does not require a specific reference to section 902.7.”) In this way, rule 2.6(6) differs from its neighbor, rule 2.6(7), which requires pleadings that rely on foreign statutes—that is, the statutes of 3As we emphasized in State v. Harris, the rules of criminal procedure have been amended recently.

11
Blockburger v. United Statesgreen
scotus · 1931 · cited in 1 Iowa opinions naming this issue, 2021–2021
2 sentences

2021Despite substituting the phrase “wholly new and different” in place of “different,” the new rule, according to Sharpe, was “merely an adoption of the prior law.” 7 v. United States, 284 U.S. 299, 304 (1932): “Under [the State’s] reasoning, offenses which lie within the chain of included offenses could be substituted, either raising or lowering the original charge.” Id.

2021Despite substituting the phrase “wholly new and different” in place of “different,” the new rule, according to Sharpe, was “merely an adoption of the prior law.” 7 v. United States, 284 U.S. 299, 304 (1932): “Under [the State’s] reasoning, offenses which lie within the chain of included offenses could be substituted, either raising or lowering the original charge.” Id.

11
Toomer v. Iowa Department of Job Servicegreen
iowa · 1983 · cited in 1 Iowa opinions naming this issue, 2021–2021
1 sentence

2021Toomer v. Iowa Dep’t of Job Serv., 340 N.W.2d 594, 597-98 (Iowa 1983) (finding that the predecessor to rule 1.981(8), which is materially identical, was “designed in part to assist [the] trial court in 15 examining the entire record before it . . . in light of the allegations in the motion.”).

11
Kroblin v. RDR Motels, Inc.green
iowa · 1984 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020The purposes of this rule “may not adequately be served to the extent that the trial court delegates to counsel its own responsibility to scrutinize the record, select apt principles of law, and fully articulate the bases for a sound, fair decision.” Kroblin v. RDR Motels, Inc., 347 N.W.2d 430, 435 (Iowa 1984) (discussing the predecessor to rule 1.904, former Iowa Rule of Civil Procedure 179(a)).

11
State v. Campbellgreen
mont · 1978 · cited in 1 Iowa opinions naming this issue, 2017–2017
2 sentences

2017A narrower gloss is consistent with Knudsen v. Chicago & North Western Transportation Co., where we allowed additional testimony about a singular event—a prior phone call—under rule 106, the predecessor of rule 5.106. 464 N.W.2d 439, 443 (Iowa 1990); see also State v. Campbell, 178 Mont. 15 , 582 P.2d 783, 785 (1978) (holding under rule of completeness, balance.or portions of the same document, correspondence, or conversation may be admitted, but not all hearsay communications regarding what the informant may have told law enforcement).

2017A narrower gloss is consistent with Knudsen v. Chicago & North Western Transportation Co., where we allowed additional testimony about a singular event—a prior phone call—under rule 106, the predecessor of rule 5.106. 464 N.W.2d 439, 443 (Iowa 1990); see also State v. Campbell, 178 Mont. 15 , 582 P.2d 783, 785 (1978) (holding under rule of completeness, balance.or portions of the same document, correspondence, or conversation may be admitted, but not all hearsay communications regarding what the informant may have told law enforcement).

11
Knudsen v. Chicago & North Western Transportation Co.green
iowa · 1990 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017A narrower gloss is consistent with Knudsen v. Chicago & North Western Transportation Co., where we allowed additional testimony about a singular event—a prior phone call—under rule 106, the predecessor of rule 5.106. 464 N.W.2d 439, 443 (Iowa 1990); see also State v. Campbell, 178 Mont. 15 , 582 P.2d 783, 785 (1978) (holding under rule of completeness, balance.or portions of the same document, correspondence, or conversation may be admitted, but not all hearsay communications regarding what the informant may have told law enforcement).

11
Walker v. Stategreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2015–2015
2 sentences

2015The district court ruled it was without jurisdiction to reinstate the case after the six-month window noted in rule 1.944(6).3 This ruling is consistent with Walker v. State, 572 N.W.2d 589, 590 (Iowa 1997), which dealt with the predecessor to rule 1.944.

2015There, the court wrote, “This court has repeatedly held that even if ‘good cause’ is shown for reinstating a case dismissed pursuant to rule 215.1, a district court lacks the authority to do so where the application for reinstatement was filed more than six months after the dismissal.” Walker, 572 N.W.2d at 590 .

11
Iowa Supreme Court Board of Professional Ethics & Conduct v. Steingreen
iowa · 1998 · cited in 1 Iowa opinions naming this issue, 2014–2014
1 sentence

2014See Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Stein, 586 N.W.2d 523, 525-26 (Iowa 1998).

11
Iowa Supreme Court Board of Professional Ethics & Conduct v. Sunleafgreen
iowa · 1999 · cited in 1 Iowa opinions naming this issue, 2014–2014
1 sentence

2014See id. at 126–27.

11
Hays v. Haysgreen
iowactapp · 2000 · cited in 1 Iowa opinions naming this issue, 2013–2013
1 sentence

2013See Hays v. Hays, 612 N.W.2d 817, 819 (Iowa Ct.App.2000) (noting that “[a] litigant may avoid the harsh consequences of [the predecessor to rule 6.101(5) ] by filing a motion to vacate or modify under [the predecessors of rules 1.1012 and 1.1013].”).

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 (11)

CaseCitedYears
State v. Walker green
iowa · 1979
2 sentences

2017Id. at 613 .

2017Id. at 613 .

32017–2017
Cook v. City of Council Bluffs green
iowa · 1978
2 sentences

2024In Cook v. City of Council Bluffs, we defined “reasonable time” for purposes of the predecessor of rule 6.101(4) as being “such time as is necessary, under the circumstances, for a reasonably prudent and diligent man to do conveniently what the contract or duty requires should be done, having regard for the rights, and possibly the loss if any to the other party affected.” Id. (emphasis added) (quoting Williamson Heater Co. v. Whitmer, 183 N.W. 404 , 405 (Iowa 1921)).

2024In Cook v. City of Council Bluffs, we defined “reasonable time” for purposes of the predecessor of rule 6.101(4) as being “such time as is necessary, under the circumstances, for a reasonably prudent and diligent man to do conveniently what the contract or duty requires should be done, having regard for the rights, and possibly the loss if any to the other party affected.” Id. (emphasis added) (quoting Williamson Heater Co. v. Whitmer, 183 N.W. 404 , 405 (Iowa 1921)).

22024–2024
State v. Luckett green
iowa · 1986
2 sentences

2024The Luckett defendant argued that “because the trial information failed to allege firearm possession” as required by Iowa Rule of Criminal Procedure 6.6 (the predecessor of rule 2.6(6)), the district court “erred in imposing a mandatory five-year sentence.” Id. at 301 .

2024The state resisted on error preservation grounds, “pointing out that [the] defendant did not object to the application of section 902.7 at the time of sentencing and did not file a post- trial motion to correct any error.” Id.

12024–2024
State v. Dann green
iowa · 1999
2 sentences

2024Id. at 636–37 On appeal, the defendant argued that the mandatory minimum sentence should not have been imposed “because the state failed to allege in the trial information that he used a dangerous weapon” as required by rule 6.6 (again, the predecessor of rule 2.6(6)).

2024Id. at 637 .

12024–2024
State v. Sharpe green
iowa · 1981
1 sentence

2021But the Sharpe court rejected the State’s request to apply a legal-elements test similar to Blockburger 7 The predecessor to rule 2.4(8) disallowed amendments if they had “the effect of charging the accused with an offense which is different than the offense which was intended to be charged in the indictment as returned by the grand jury.” Sharpe, 304 N.W.2d at 222 (quoting Iowa Code § 773.46 (1977)).

12021–2021
In Re the Marriage of Thielges green
iowactapp · 2000
1 sentence

2018Evid. 5.403; Thielges, 623 N.W.2d at 239–40 (citing the predecessor to rule 5.403).

12018–2018
Hackett v. Freeman & Graves green
iowa · 1897
2 sentences

1992Hack-ett, interpreting a statute that was a predecessor to rule 609, made two points: (1) the term conviction “includes both the ascertaining of the guilt of the accused and judgment thereon by the court”; and (2) the pendency of an appeal neither annuls a conviction nor renders it incompetent for purposes of impeachment. 103 Iowa at 298-300 , 72 N.W. at 529 .

1992Hack-ett, interpreting a statute that was a predecessor to rule 609, made two points: (1) the term conviction “includes both the ascertaining of the guilt of the accused and judgment thereon by the court”; and (2) the pendency of an appeal neither annuls a conviction nor renders it incompetent for purposes of impeachment. 103 Iowa at 298-300 , 72 N.W. at 529 .

11992–1992
Perry v. Kaspar neutral
iowa · 1901
2 sentences

1985Id. at 274 , 85 N.W. at 23 .

1985Id. at 274 , 85 N.W. at 23 .

11985–1985
City of Des Moines v. Elliott green
iowa · 1978
1 sentence

1984The prior provision, Iowa Code section 795.2 (1977), was interpreted in City of Des Moines v. Elliott, 267 N.W.2d 44 (Iowa 1978).

11984–1984
State v. O'CONNELL green
iowa · 1979
1 sentence

1981We addressed this issue in State v. O’Connell, 275 N.W.2d 197 (Iowa 1979), which was decided under section 795.2, The Code 1975, the predecessor of rule 27(2)(b).

11981–1981
Penland v. Penland green
iowa · 1963
1 sentence

1979The appeal was considered as an application for writ of certiorari and the writ was issued. 258 Iowa at 313, 122 N.W.2d at 336 .

11979–1979

Statutes the citing opinions construe

IA § Iowa Code § 703.1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 83 (1980–2026) TX 76 (1988–2024) MD 33 (1973–2016) FL 30 (1967–2025) IA 27 (1979–2026) MI 16 (1968–2025) NJ 12 (1974–2022) MO 10 (1980–2021) WA 10 (1979–2011) UT 10 (1989–2025) OR 9 (1988–2026) PA 7 (2019–2026) AL 7 (1954–2003) MS 5 (1994–2003) MA 4 (1985–2010) HI 4 (2003–2026) NY 3 (1948–1995) IN 3 (2000–2010) ID 3 (2023–2024) DC 3 (1977–2003) MN 3 (1977–2015) VA 2 (1997–2012) WY 2 (1986–1986) AZ 2 (1975–1977) NM 2 (1983–2023)

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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