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

23 Iowa opinions name it 2 courts 1992–2025 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 (23)

CaseFollowedCited
State Of Iowa Vs. Jason Allen Winggreen
iowa · 2010 · cited in 3 Iowa opinions naming this issue, 2015–2015
2 sentences

2015Id.; see also id. at 255 (Cady, J., dissenting) (explaining the “held to answer” language from the previous version of the rule related to the initial court appearance).

2015Id.; see also id. at 255 (Cady, J., dissenting) (explaining the “held to answer” language from the previous version of the rule related to the initial court appearance).

33
Iowa Supreme Court Board of Professional Ethics & Conduct v. Jonesgreen
iowa · 2000 · cited in 2 Iowa opinions naming this issue, 2013–2021
2 sentences

2021Ethics & Conduct v. Jones, 606 N.W.2d 5, 6, 9 (Iowa 2000) (en banc) (per curiam) (holding the former version of rule 32:8.4(c) was violated in part because Jones failed to disclose that the transaction was very risky, and in part because he had failed to reveal he had taken a contingent interest in the transaction).

2013Jones, 606 N.W.2d at 6, 9 .

22
Bride v. Heckartgreen
iowa · 1996 · cited in 2 Iowa opinions naming this issue, 2016–2016
2 sentences

2016Under our existing precedents interpreting the language in rule 51:2.11(A), it is clear that a judge who fails to disqualify himself or herself from a proceeding in which an attorney who recently represented the judge in a personal matter represents a party violates rule 51:2.11(A) unless the judge complies with rule 51:2.11(0 by disclosing the relevant facts to and obtaining a disqualification waiver from both parties in advance. 4 See Bride v. Heckart, 556 N.W.2d 449, 455 (Iowa 1996) (relying on a prior interpretation of the language in the prior version of rule 51:2.11(A)); Forsmark v. Stat

2016Under our existing precedents interpreting the language in rule 51:2.11(A), it is clear that a judge who fails to disqualify himself or herself from a proceeding in which an attorney who recently represented the judge in a personal matter represents a party violates rule 51:2.11(A) unless the judge complies with rule 51:2.11(C) by disclosing the relevant facts to and obtaining a disqualification waiver from both parties in advance. 4 See Bride v. Heckart, 556 N.W.2d 449, 455 (Iowa 1996) (relying on a prior interpretation of the language in the prior version of rule 51:2.11(A)); Forsmark v. Sta

22
State v. Manngreen
iowa · 1994 · cited in 2 Iowa opinions naming this issue, 2016–2016
2 sentences

2016State v. Mann, 512 N.W.2d 528, 532 [Iowa 1994) (addressing nearly identical language in the prior version of rule 51:2.11).

2016State v. Mann, 512 N.W.2d 528, 532 (Iowa 1994) (addressing nearly identical language in the prior version of rule 51:2.11).

22
Forsmark v. Stategreen
iowa · 1984 · cited in 2 Iowa opinions naming this issue, 2016–2016
2 sentences

2016Under our existing precedents interpreting the language in rule 51:2.11(A), it is clear that a judge who fails to disqualify himself or herself from a proceeding in which an attorney who recently represented the judge in a personal matter represents a party violates rule 51:2.11(A) unless the judge complies with rule 51:2.11(0 by disclosing the relevant facts to and obtaining a disqualification waiver from both parties in advance. 4 See Bride v. Heckart, 556 N.W.2d 449, 455 (Iowa 1996) (relying on a prior interpretation of the language in the prior version of rule 51:2.11(A)); Forsmark v. Stat

2016Under our existing precedents interpreting the language in rule 51:2.11(A), it is clear that a judge who fails to disqualify himself or herself from a proceeding in which an attorney who recently represented the judge in a personal matter represents a party violates rule 51:2.11(A) unless the judge complies with rule 51:2.11(C) by disclosing the relevant facts to and obtaining a disqualification waiver from both parties in advance. 4 See Bride v. Heckart, 556 N.W.2d 449, 455 (Iowa 1996) (relying on a prior interpretation of the language in the prior version of rule 51:2.11(A)); Forsmark v. Sta

12
Brown v. First National Bank of Mason Citygreen
iowa · 1972 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025Restatement (Second) of Torts § 598; see also Brown v. First Nat’l Bank, 193 N.W.2d 547 , 552–53 (Iowa 1972) (discussing a former version of this rule but 7 See, e.g., Kelley v. Tanoos, 865 N.E.2d 593, 600 (Ind. 2007); Kennedy v. Sheriff of E.

11
Kelley v. Tanoosgreen
ind · 2007 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025Restatement (Second) of Torts § 598; see also Brown v. First Nat’l Bank, 193 N.W.2d 547 , 552–53 (Iowa 1972) (discussing a former version of this rule but 7 See, e.g., Kelley v. Tanoos, 865 N.E.2d 593, 600 (Ind. 2007); Kennedy v. Sheriff of E.

11
State v. Oetkengreen
iowa · 2000 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See State v. Oetken, 613 N.W.2d 679 , 686–87 (Iowa 2000) (approving this procedure and rejecting the defendant’s argument that the substituted trial information without the habitual-offender enhancement replaced the one previously filed); see also State v Bruegger, 773 N.W.2d 862 , 869–70 (Iowa 2009) (concluding a “supplemental information” was simply designed to comply with rule 2.6(5)).

11
State v. Brueggergreen
iowa · 2009 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See State v. Oetken, 613 N.W.2d 679 , 686–87 (Iowa 2000) (approving this procedure and rejecting the defendant’s argument that the substituted trial information without the habitual-offender enhancement replaced the one previously filed); see also State v Bruegger, 773 N.W.2d 862 , 869–70 (Iowa 2009) (concluding a “supplemental information” was simply designed to comply with rule 2.6(5)).

11
State of Iowa v. Donald James Hillgreen
iowa · 2016 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See, e.g., State v. Hill, 878 N.W.2d 269, 273 (Iowa 2016) (requiring district courts to give reasons for imposing consecutive sentences under an earlier version of rule 2.23).

11
State v. LeFloregreen
iowa · 1981 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See State v. LeFlore, 308 N.W.2d 39, 41 (Iowa 1981) (stating “the statutory right to a speedy trial under [the former version of rule 2.33(2)(b)] is not a personal right that can be waived only by the defendant” and “[d]efense counsel acting within the scope of his or her authority may waive this right on the defendant's behalf without the defendant’s express consent”).

11
Top of Iowa Cooperative v. Sime Farms, Inc.green
iowa · 2000 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See Top of Iowa Coop v. Sime Farms, Inc., 608 N.W.2d 454, 470 (Iowa 2000) (“[O]ne purpose of our error preservation rules is to ensure that the opposing 1 Under Iowa Rule of Evidence 601 (1985), “a child [was] presumed to be competent.” But if the child’s competency was questioned, then the court was required to determine: (1) the child is mentally capable of understanding the questions being asked; (2) the child is able to formulate intelligent answers and communicate impressions and recollections regarding the incident about which the child is to testify; and (3) the child can understand the

11
State of Iowa v. Antoine Tyree Williamsgreen
iowa · 2019 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023More recently, our supreme court approved of a very similar version of instruction 5 in State v. Williams, 929 N.W.2d 621, 633 (Iowa 2019).

11
Boham v. City of Sioux City, Iowagreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023He did not make any objection to duplicative reasonable care specifications in Instruction 15, as he does on appeal. 5 Under Iowa Rule of Civil Procedure 1.924, “[w]e may only consider on appeal those objections to instructions previously raised with the trial court.” Grefe & Sidney, 525 N.W.2d at 824 (citing a former version of rule 1.924); accord Boham v. City of Sioux City, 567 N.W.2d 431, 438 (Iowa 1997) (“A party may not amplify or change an objection on appeal.”).

11
DeVoss v. Stategreen
iowa · 2002 · cited in 1 Iowa opinions naming this issue, 2018–2018
1 sentence

2018See DeVoss v. State, 648 N.W.2d 56, 63 (Iowa 2002) (declining to consider issue for the first time on appeal, even if it is the only ground available to uphold a district court ruling).

11
IA SUPREME CT. ATTY. DISC. BD. v. Morrisongreen
iowa · 2007 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016We have said that “the professional relationship renders it impossible for the vulnerable layperson to be considered ‘consenting’ ” to the sexual relationship, Jowa Supreme Ct. Att’y Disciplinary Bd. v. Marzen, 779 N.W.2d 757, 760 (Iowa 2010) (quoting Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Furlong, 625 N.W.2d 711, 714 (Iowa 2001)); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Morrison, 727 N.W.2d 115, 118 (Iowa 2007) (discussing the prior version of the rule in the Code of Professional Responsibility and delineating four separate reasons for it).

11
Iowa Supreme Court Board of Professional Ethics & Conduct v. Furlonggreen
iowa · 2001 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016We have said that “the professional relationship renders it impossible for the vulnerable layperson to be considered ‘consenting’ ” to the sexual relationship, Jowa Supreme Ct. Att’y Disciplinary Bd. v. Marzen, 779 N.W.2d 757, 760 (Iowa 2010) (quoting Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Furlong, 625 N.W.2d 711, 714 (Iowa 2001)); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Morrison, 727 N.W.2d 115, 118 (Iowa 2007) (discussing the prior version of the rule in the Code of Professional Responsibility and delineating four separate reasons for it).

11
Iowa Supreme Court Attorney Disciplinary Board v. Marzengreen
iowa · 2010 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016We have said that “the professional relationship renders it impossible for the vulnerable layperson to be considered ‘consenting’ ” to the sexual relationship, Jowa Supreme Ct. Att’y Disciplinary Bd. v. Marzen, 779 N.W.2d 757, 760 (Iowa 2010) (quoting Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Furlong, 625 N.W.2d 711, 714 (Iowa 2001)); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Morrison, 727 N.W.2d 115, 118 (Iowa 2007) (discussing the prior version of the rule in the Code of Professional Responsibility and delineating four separate reasons for it).

11
State v. Glenngreen
iowactapp · 1988 · cited in 1 Iowa opinions naming this issue, 2015–2015
2 sentences

2015“The court is not required to use any particular language to satisfy rule 22(3)(d).” State v. Glenn, 431 N.W.2d 193, 194 (Iowa Ct. App. 1988) (discussing a former version of rule 2.23(3)(d)).

2015“Substantial compliance is sufficient.” Id.

11
State of Iowa v. John Penn-Kennedygreen
iowa · 2015 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015Id. (“An arrest is the triggering event to commence the forty-five-day time period to file an indictment under the rule, supplanting the previous version of the rule’s use of the date of prosecution as the trigger.”); see also Wing, 791 N.W.2d at 255 (Cady, J. dissenting).

11
Iowa Supreme Court Board of Professional Ethics & Conduct v. D.J.I.green
iowa · 1996 · cited in 1 Iowa opinions naming this issue, 2012–2012
1 sentence

2012Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. D.J.I., 545 N.W.2d 866, 871 (Iowa 1996) (observing under the former version of rule 35.7(3), rule 118.7, that issue preclusion “may be used by either party in a lawyer discipline case”).

11
In the Interest of A.G.green
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2000–2000
1 sentence

2000In re A.G., 558 N.W.2d 400, 403 (Iowa 1997).

11
City of Webster City v. Draheimgreen
iowa · 1980 · cited in 1 Iowa opinions naming this issue, 1992–1992
1 sentence

1992See City of Webster City v. Draheim, 292 N.W.2d 406, 409 (Iowa 1980).

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
Higgins v. Iowa Department of Job Service green
iowa · 1984
2 sentences

2016Id. (emphasis omitted); see Iowa Admin.

2016The record revealed “seven instances of absenteeism resulting from personal problems or predicaments[,] . . . includ[ing] oversleeping, delays caused by tardy babysitters, car trouble, and no excuse.” Higgins, 350 N.W.2d at 191 .

22016–2016
In the Matter of Douglas A. KRULL, Judicial Magistrate green
iowa · 2015
2 sentences

2016In other words, the test is not whether the judge actually questions his or her own impartiality, “but whether a reasonable person would question it.” Krull, 860 N.W.2d at 44 (quoting Mann, 512 N.W.2d at 532 ).

2016In other words, the test is not whether the judge actually questions his or her own impartiality, “but whether a reasonable person would question it.” Krull, 860 N.W.2d at 44 (quoting Mann, 512 N.W.2d at 532 ).

22016–2016
Kennedy v. Sheriff of East Baton Rouge green
la · 2006
1 sentence

2025Baton Rouge, 935 So. 2d 669 , 682–83 (La. 2006). 15 finding it did not apply because the communication was made to the general public).

12025–2025
Grefe & Sidney v. Watters green
iowa · 1994
1 sentence

2023He did not make any objection to duplicative reasonable care specifications in Instruction 15, as he does on appeal. 5 Under Iowa Rule of Civil Procedure 1.924, “[w]e may only consider on appeal those objections to instructions previously raised with the trial court.” Grefe & Sidney, 525 N.W.2d at 824 (citing a former version of rule 1.924); accord Boham v. City of Sioux City, 567 N.W.2d 431, 438 (Iowa 1997) (“A party may not amplify or change an objection on appeal.”).

12023–2023
Iowa Supreme Court Attorney Disciplinary Board v. Robert Allan Wright Jr. green
iowa · 2013
1 sentence

2021A similar scenario presented itself in Iowa Supreme Court Attorney Disciplinary Board v. Wright, where an attorney utilized funds from five clients to assist another client obtain what he believed was an inheritance from a cousin in Nigeria. 840 N.W.2d at 297–98.

12021–2021
State v. Bair green
iowa · 1985
2 sentences

2015The earlier version of the rule did not contain a reference to a “common scheme or plan.” Id.

2015The court acknowledged the subsequent amendment “liberalize[d] and broaden[ed] charging practices so as to allow prosecutors more leeway in seeking to join multiple offenses for a single prosecution.” Id.

12015–2015

Statutes the citing opinions construe

IA § Iowa Code § 602.9206 (4) IA § Iowa Code § 804.1 (3) IA § Iowa Code § 804.14 (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 122 (1944–2026) FL 81 (1979–2026) TX 65 (1976–2026) IL 65 (1980–2025) UT 64 (1982–2026) PA 32 (1978–2024) OH 31 (1999–2026) MO 28 (1951–2023) WA 28 (1980–2024) OR 27 (1991–2024) CO 27 (1969–2025) IA 23 (1992–2025) MI 23 (1981–2026) MD 17 (1983–2023) MA 15 (1980–2025) NJ 15 (1976–2024) IN 14 (1975–2024) WI 13 (1980–2023) CT 13 (1992–2025) AK 11 (1990–2025) NY 10 (1965–2025) GA 10 (1972–2024) AZ 9 (1978–2018) NM 9 (1994–2024) KS 8 (1995–2024) WY 8 (1957–2017) DC 8 (1997–2007) ID 7 (1991–2021) MS 6 (1991–2017) ND 6 (2000–2024) NC 6 (2004–2023) KY 5 (2008–2024) LA 5 (1979–2009) AR 5 (2000–2022) MN 4 (2003–2015) WV 3 (2004–2012) TN 3 (1976–2023) AL 3 (2006–2024) OK 3 (2013–2014) VA 3 (2009–2024) SC 2 (1984–1984) HI 2 (1996–1996) NV 2 (2021–2023)

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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