typographical error in Iowa

2017See, e.g., In re D.L.C., 464 N.W.2d 881, 883 (Iowa 1991) (noting the juvenile court’s error was harmless in light of the de novo review of the appellate court).

2015See, e.g., In re D.L.C., 464 N.W.2d 881, 883 (Iowa 1991) (noting the juvenile court’s error was harmless in light of the de novo review of the appellate court).

2022We therefore choose to focus on termination under paragraph (f). 8 custody of the child’s parents”); In re D.W., 791 N.W.2d 703, 707 (Iowa 2010) (interpreting the statutory language “at the present time” to mean “at the time of the termination hearing”).

2020The father also asserts that the State failed to prove the fourth element of termination in sections 232.116(1)(f) and 232.116(1)(h), specifically that “there is clear and convincing evidence that at the present time the child cannot be returned to the custody of the child’s parents as provided in section 232.102.” See Iowa Code § 232.116 (1)(f)(4), (h)(4); In re D.W., 791 N.W.2d 703, 707 (Iowa 2010) (interpreting the statutory language “at the present time” to mean “at the time of the termination hearing”).

2025See In re P.L., 778 N.W.2d 33, 40 (Iowa 2010) (When a parent does not dispute the existence of grounds under section 232.116, “we do not have to discuss this step”).

2025Thi s apparent typo does not support sanctions. 12 signed. “[T]here [i]s no continuing duty under [the] sanction rule.” Mathias, 448 N.W.2d at 447; see also Schettler, 509 N.W.2d at 465 (“Mathias specifically rejected any notion that Rule [1.413(1)] imposes a continuing duty on the signer to dismiss the action if the signer later learns the client has no case.”).

2025This apparent typo does not support sanctions. 12 signed. “[T]here [i]s no continuing duty under [the] sanction rule.” Mathias, 448 N.W.2d at 447 ; see also Schettler, 509 N.W.2d at 465 (“Mathias specifically rejected any notion that Rule [1.413(1)] imposes a continuing duty on the signer to dismiss the action if the signer later learns the client has no case.”).

2025Thi s apparent typo does not support sanctions. 12 signed. “[T]here [i]s no continuing duty under [the] sanction rule.” Mathias, 448 N.W.2d at 447; see also Schettler, 509 N.W.2d at 465 (“Mathias specifically rejected any notion that Rule [1.413(1)] imposes a continuing duty on the signer to dismiss the action if the signer later learns the client has no case.”).

2025This apparent typo does not support sanctions. 12 signed. “[T]here [i]s no continuing duty under [the] sanction rule.” Mathias, 448 N.W.2d at 447 ; see also Schettler, 509 N.W.2d at 465 (“Mathias specifically rejected any notion that Rule [1.413(1)] imposes a continuing duty on the signer to dismiss the action if the signer later learns the client has no case.”).

2025If the drawing was destroyed, [Crow]’s remedy, if any, is beyond the scope of this proceeding. 2 Throughout its ruling, the district court refers to the Gregory injunction as the Gilbert injunction, a typographical error irrelevant to our review. 3 See Kelly v. Brewer, 239 N.W.2d 109, 113 (Iowa 1976) (upholding solitary confinement for purposes of discipline). 4 The State petitioned for a writ of certiorari.

2024Paragraph (h) is not one of the grounds relied upon by the juvenile court, but even if we assume this is a typographical error and the father meant to challenge 3 (“A broad, all encompassing argument is insufficient to identify error in cases of de novo review.”); Hyler v. Garner, 548 N.W.2d 864, 876 (1996) (“[W]e will not speculate on the arguments [a party] might have made and then search for legal authority and comb the record for facts to support such arguments.”); Inghram v. Dairyland Mut.

2024See Covert, 35 N.W. at 637 ; Eckford v. Eckford, 58 N.W. 1093 , 1093 (Iowa 1894); Fox, 2002 WL 1585621 , at *3.

2023See In re A.A., No. 21-1972, 2022 WL 946503 , at *3 (Iowa Ct. App. Mar. 30, 2022) (“The erroneous reference to paragraph (f), a presumed typographical error, therefore ‘has no legal significance.’” (citation omitted)); see also In re H.C., No. 16-1961, 2017 WL 512798, at *2 (Iowa Ct. App. Feb. 8, 2017) (“[W]e decline to place form over substance and waste judicial resources on what was clearly a clerical error.”). 3 P. 6 .201(1)(d) (“The petition on appeal shall substantially comply with form 5 in rule 6.1401.”); .1401–Form 5 (requiring separate issue headings and other requirements for each i

2023See In re A.A., No. 21-1972, 2022 WL 946503 , at *3 (Iowa Ct. App. Mar. 30, 2022) (“The erroneous reference to paragraph (f), a presumed typographical error, therefore ‘has no legal significance.’” (citation omitted)); see also In re H.C., No. 16-1961, 2017 WL 512798, at *2 (Iowa Ct. App. Feb. 8, 2017) (“[W]e decline to place form over substance and waste judicial resources on what was clearly a clerical error.”). 3 P. 6 .201(1)(d) (“The petition on appeal shall substantially comply with form 5 in rule 6.1401.”); .1401–Form 5 (requiring separate issue headings and other requirements for each i

2023But as noted, the father does not challenge this ground. 5 record.” In re A.B., 815 N.W.2d 764, 774 (Iowa 2012).

2023See In re C.B., 611 N.W.2d 489, 492 (Iowa 2000) (“We have long recognized an appellant must identify alleged error on appeal.”).

2018See In re Z.C., No. 17-0666, 2017 WL 1735913, at *2 (Iowa Ct. App. May 3, 2017) (finding the court’s reference to paragraph (h) was “clearly a typographical error, which is harmless given our de novo review,” and analyzing instead whether the grounds for termination had been proved under paragraph (f)). 4 Chapter 232 defines “abandonment of a child” as “the relinquishment or surrender . . . of the parental rights, duties, or privileges inherent in the parent-child relationship.” Iowa Code § 232.2 (1).

2018See State v. Utter, 803 N.W.2d 647, 651 (Iowa 2011), overruled on other grounds by Schmidt v. State, 909 N.W.2d 778, 789 (Iowa 2018).

2018See State v. Utter, 803 N.W.2d 647, 651 (Iowa 2011), overruled on other grounds by Schmidt v. State, 909 N.W.2d 778, 789 (Iowa 2018).

2018CONVICTIONS AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS. 1 Bartlett's motion to dismiss contains a typographical error that the arrest warrant issued on "October 22, 2016." 2 See Williams , 895 N.W.2d at 867 (holding the speedy indictment rule "is triggered from the time a person is taken into custody, but only when the arrest is completed by taking the person before a magistrate for an initial appearance ") (emphasis added).

2014See State v. Yarborough, 536 N.W.2d 493, 497 (Iowa Ct. App. 1995).

2014See State v. Williams, 695 N.W.2d 23, 28 (Iowa 2005).