plain language rule (Iowa) · Go Syfert
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plain language rule in Iowa

24 Iowa opinions name it 2 courts 1978–2026 5 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
Brisson v. Stategreen
wyo · 1998 · cited in 3 Iowa opinions naming this issue, 2015–2015
2 sentences

2015See Brisson, 955 P.2d at 891 .

2015See Brisson, 955 P.2d at 891 .

33
State of Iowa v. Christopher George Stormgreen
iowa · 2017 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See Storm, 898 N.W.2d at 163, 165 (Hecht, J., dissenting) (outlining nonexhaustive list of exceptions to 31 plain-language rule).

2017See Storm, 898 N.W.2d at 163, 165 (Hecht, J., dissenting) (outlining nonexhaustive list of exceptions to plain-language rule).

22
Rock v. Warhankgreen
iowa · 2008 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009“When the language of a statute is plain and its meaning clear, the rules of statutory construction do not permit us to search for meaning beyond the statute’s express terms.” Rock v. Warhank, 757 N.W.2d 670, 673 (Iowa 2008).

2009“When the language of a statute is plain and its meaning clear, the rules of statutory construction do not permit us to search for meaning beyond the statute’s express terms.” Rock v. Warhank, 757 N.W.2d 670, 673 (Iowa 2008).

22
Paige v. City of Charitongreen
iowa · 1977 · cited in 2 Iowa opinions naming this issue, 1978–1990
2 sentences

1990By the plain language of rule 236 good cause must be based on (1) mistake, (2) inadvertence, (3) surprise, (4) excusable neglect, or (5) unavoidable casualty." In re Marriage of Huston, 263 N.W.2d 697, 698 (Iowa 1978), quoting Paige v. City of Chariton, 252 N.W.2d 433, 437 (Iowa 1977).

1990By the plain language of rule 236 good cause must be based on (1) mistake, (2) inadvertence, (3) surprise, (4) excusable neglect, or (5) unavoidable casualty.” In re Marriage of Huston, 263 N.W.2d 697, 698 (Iowa 1978), quoting Paige v. City of Chariton, 252 N.W.2d 433, 437 (Iowa 1977).

22
Embassy Tower Care, Inc. v. Tweedygreen
iowa · 1994 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026Embassy Tower Care, Inc. v. Tweedy, 516 N.W.2d 831, 834 (Iowa 1994) (holding that the plain language of the rule “makes clear . . . that it applies only when a trial has previously been held”). 2 Under Iowa Rule of Civil Procedure 1.1013(1), [a] petition for relief under rule 1.1012 requires payment of the filing fee set forth in Iowa Code section 602.8105(1)(a), or if made in small claims, the filing fee set forth in section 631.6(1)(a), and must be filed and served in the original action within one year after the entry of the judgment or order involved.

11
State v. Delaygreen
iowa · 1982 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026But as the State asserts “justification is an affirmative defense rather than an element.” See State v. Delay, 320 N.W.2d 831, 833 (Iowa 1982) (emphasis added); see also White v. Harkrider, 990 N.W.2d 647 , 656 (Iowa 2023) (listing cases describing justification as an affirmative defense).

11
State of Iowa v. Kevin Duane Fisher IIgreen
iowa · 2016 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025To determine whether the requirements of rule 2.8(2)(d) were met, “[w]e employ a substantial compliance standard.” Fisher, 877 N.W.2d at 681 (citation omitted).

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

2024Indeed, we have said a “foundational element[]” of the rule is that the proffered evidence must be a “business record.” State v. Reynolds, 746 N.W.2d 837, 841 (Iowa 2008); see also Beachel v. Long, 420 N.W.2d 482, 484 (Iowa Ct. App. 1998).

11
State v. Reynoldsgreen
iowa · 2008 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024Indeed, we have said a “foundational element[]” of the rule is that the proffered evidence must be a “business record.” State v. Reynolds, 746 N.W.2d 837, 841 (Iowa 2008); see also Beachel v. Long, 420 N.W.2d 482, 484 (Iowa Ct. App. 1998).

11
State of Iowa v. Wendell Karl Harringtongreen
iowa · 2011 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015State v. Harrington, 800 N.W.2d 46, 50 (Iowa 2011) (“The plain language of rule 5.609(a)(2), however, leaves the district court no similar discretion.

11
Saadiq v. Stategreen
iowa · 1986 · cited in 1 Iowa opinions naming this issue, 1997–1997
1 sentence

1997See Saadiq v. State, 387 N.W.2d 315, 319 (Iowa 1986) (when meaning of statute is clear, appellate court may not search for a meaning beyond the clear language).

11
State v. Beeksgreen
iowactapp · 1988 · cited in 1 Iowa opinions naming this issue, 1997–1997
1 sentence

1997See State v. Beeks, 428 N.W.2d 307, 309 (Iowa App.1988) (speedy indictment rule commenced upon the arrest for the offense charged in the existent proceedings.) The broad construction suggested by Edwards is beyond the plain language of the rule.

11
State v. Swansongreen
iowactapp · 1989 · cited in 1 Iowa opinions naming this issue, 1995–1995
1 sentence

1995See State v. Swanson, 452 N.W.2d 466, 468 (Iowa App.1989).

11
State v. Hunzikergreen
iowactapp · 1981 · cited in 1 Iowa opinions naming this issue, 1992–1992
1 sentence

1992State v. Hunziker, 311 N.W.2d 692, 693 (Iowa App.1981).

11
In Re the Marriage of Hustongreen
iowa · 1978 · cited in 1 Iowa opinions naming this issue, 1990–1990
2 sentences

1990By the plain language of rule 236 good cause must be based on (1) mistake, (2) inadvertence, (3) surprise, (4) excusable neglect, or (5) unavoidable casualty." In re Marriage of Huston, 263 N.W.2d 697, 698 (Iowa 1978), quoting Paige v. City of Chariton, 252 N.W.2d 433, 437 (Iowa 1977).

1990By the plain language of rule 236 good cause must be based on (1) mistake, (2) inadvertence, (3) surprise, (4) excusable neglect, or (5) unavoidable casualty.” In re Marriage of Huston, 263 N.W.2d 697, 698 (Iowa 1978), quoting Paige v. City of Chariton, 252 N.W.2d 433, 437 (Iowa 1977).

11
International Shoe Co. v. Washingtongreen
scotus · 1945 · cited in 1 Iowa opinions naming this issue, 1989–1989
2 sentences

1989The clear implication of the argument is that a class action plaintiff, like the customary defendant, must have “ ‘certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend ‘traditional notions of fair play and sub *876 stantial justice.’ ” Smalley v. Dewberry, 379 N.W.2d 922, 924 (Iowa 1986) (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154, 158 , 90 L.Ed. 95, 102 (1945)).

1989The clear implication of the argument is that a class action plaintiff, like the customary defendant, must have “ ‘certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend ‘traditional notions of fair play and sub *876 stantial justice.’ ” Smalley v. Dewberry, 379 N.W.2d 922, 924 (Iowa 1986) (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154, 158 , 90 L.Ed. 95, 102 (1945)).

11
Smalley v. Dewberrygreen
iowa · 1986 · cited in 1 Iowa opinions naming this issue, 1989–1989
1 sentence

1989The clear implication of the argument is that a class action plaintiff, like the customary defendant, must have “ ‘certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend ‘traditional notions of fair play and sub *876 stantial justice.’ ” Smalley v. Dewberry, 379 N.W.2d 922, 924 (Iowa 1986) (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154, 158 , 90 L.Ed. 95, 102 (1945)).

11
State v. Schmittgreen
iowa · 1980 · cited in 1 Iowa opinions naming this issue, 1981–1981
1 sentence

1981State v. Schmitt, 290 N.W.2d 24, 26-28 (Iowa 1980) (apprehension of escapee constituted arrest, commencing forty-five-day period of rule 27(2)(a)).

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 (6)

CaseCitedYears
TLC Home Health Care, L.L.C. v. Iowa Department of Human Services green
iowa · 2002
2 sentences

2009Although we give an agency substantial deference when it interprets its own regulations, TLC Home Health Care, L.L.C. v. Iowa Dep’t of Human Servs., 638 N.W.2d 708 (Iowa 2002), the plain language of the rule is clear and unambiguous.

2009Although we give an agency substantial deference when it interprets its own regulations, TLC Home Health Care, L.L.C. v. Iowa Dep’t of Human Servs., 638 N.W.2d 708 (Iowa 2002), the plain language of the rule is clear and unambiguous.

22009–2009
Mathias v. Glandon green
iowa · 1989
2 sentences

2025Later-acquired information is not generally relevant to the rule 1.413(1) sanctions inquiry because the plain language of the rule “clearly expresses an intent that the court evaluate the signer’s conduct at the time of signing the pleading, motion, or other paper.” Id.

2025Later-acquired information is not generally relevant to the rule 1.413(1) sanctions inquiry because the plain language of the rule “clearly expresses an intent that the court evaluate the signer’s conduct at the time of signing the pleading, motion, or other paper.” Id.

12025–2025
State v. Edwards green
iowactapp · 1997
1 sentence

2014The plain language of rule 2.33 “restricts the speedy indictment mandate to the offense or offenses for which the defendant was arrested, and does not extend to a different offense not charged in the complaint related to the arrest.” Edwards, 571 N.W.2d at 499 .

12014–2014
Office of Consumer Advocate v. Iowa Utilities Board green
iowa · 2008
1 sentence

2011If the Board now wishes to include these services within the definition of cramming, it should use the rule making process to redefine cramming by eliminating the exceptions that are currently listed and not resort to “[m]aking policy by ad hoc decisions on a case-by-ease basis.” Office of Consumer Advocate, 744 N.W.2d at 646 .

12011–2011
Iowa Supreme Court Board of Professional Ethics & Conduct v. Lett green
iowa · 2004
1 sentence

2011The plain language of this rule addresses the obligation of lawyers to be attentive and responsive to circumstances in which a client’s mental or legal capacity is impaired and to take “reasonably necessary protective action, including consulting with individuals or entities that have the ability to take action to protect the client, and, in appropriate cases, seeking the appointment of a guardian ad litem, conservator, or guardian.” Id. r. 32:1.14(b).

12011–2011
State v. Sunclades green
iowa · 1981
1 sentence

1983He cites our language in State v. Sunclades, 305 N.W.2d 491 (Iowa 1981), where on page 494 we stated “the plain language of rule 27(2)(a) provides that the period of time in which an indictment must be returned commences when the defendant is arrested.” This language was used in our discourse concerning our conclusion that the arrest for the charged crime triggered the time period rather than a prior arrest for another public offense arising out of the same charge.

11983–1983

Statutes the citing opinions construe

IA § Iowa Code § 714.2 (4) IA § Iowa Code § 17A.19 (3) IA § Iowa Code § 321.209 (3) IA § Iowa Code § 692A.103 (3) USC § 20u.s.c.1091 (3) USC § 42u.s.c.1437d(l)(6) (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

TX 152 (1989–2025) IL 149 (1893–2026) UT 136 (1993–2026) WA 125 (1996–2026) FL 114 (1970–2026) CA 72 (1943–2026) MN 68 (1964–2025) OH 62 (1988–2026) MI 56 (1981–2025) NM 53 (1998–2025) AZ 52 (1985–2025) PA 52 (1974–2026) MD 41 (1982–2025) HI 38 (1994–2026) NJ 30 (1991–2026) AL 29 (1997–2018) MO 26 (1961–2024) CO 24 (1992–2026) IA 24 (1978–2026) IN 19 (1979–2024) ME 18 (1997–2024) ID 15 (2008–2024) MA 15 (1990–2023) WI 14 (1979–2025) KY 13 (2001–2024) NY 13 (1991–2026) VT 13 (1993–2025) GA 12 (1991–2023) AR 12 (1994–2026) TN 12 (1991–2022) NV 12 (2012–2022) NC 10 (1992–2024) MS 10 (1999–2018) WY 10 (1976–2025) AK 10 (1980–2023) DC 9 (1982–2019) NH 8 (1978–2025) ND 8 (1911–2016) VA 7 (2005–2010) CT 7 (1982–2022) RI 5 (1985–2014) KS 4 (2011–2019) MT 4 (2007–2020) SD 4 (1992–1997) SC 4 (1992–2019) GU 3 (2021–2026) VI 3 (2001–2015) LA 3 (2006–2013) NE 3 (2005–2006) DE 3 (2018–2021) WV 3 (2014–2024) OR 3 (2000–2022) OK 2 (1945–2000)

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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