appellate review that issues must ordinarily doctrine in Iowa

2026See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”).

2026See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”). 3 This provision states that an actor in a special relationship with another, which includes “a business or other possessor of land that holds its premises open to the public,” “owes the other a duty of reasonable care with regard to risks that arise within the scope of the relationship.” Restatement (Third) § 40(a), (b)(3). 11 For these reasons, we affirm the district court’

2026“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (citation omitted).

2026See Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citation omitted)).

2021See Bank of Am., N.A. v. Schulte, 843 N.W.2d 876, 883 (Iowa 2014) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citation omitted)). 3.

2021See Bank of Am., N.A. v. Schulte, 843 N.W.2d 876, 883 (Iowa 2014) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citation omitted)).

2021See Meier v. Senecaut, 641 5 N.W.2d 532 , 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also State v. Mulvaney, 600 N.W.2d 291, 293 (Iowa 1999) (“[W]e require error preservation even on constitutional issues.”).

2020See Meier v. Senecaut, 5 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also State v. Mulvany, 600 N.W.2d 291, 293 (Iowa 1999) (“[W]e require error preservation even on constitutional issues.”).

2025“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002); see also A.B., 815 N.W.2d at 773 (“[T]he general rule that appellate arguments must first be raised in the trial court applies to [child in need of assistance] and termination of parental rights cases.”).

2025See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also In re A.B., 815 N.W.2d 764, 773 (Iowa 2012) (applying this doctrine to termination proceedings).

2023“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (citing Metz v. Amoco Oil Co., 581 N.W.2d 597, 600 (Iowa 1998) (en banc)).

2020See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citing Metz v. Amoco Oil Co., 581 N.W.2d 597, 600 (Iowa 1998))).

2019“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.” In re K.C., 660 N.W.2d 29, 38 (Iowa 2003); see also Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”).

2019First, we find the father has failed to preserve the lack-of-consent issue for our review as he raises it for the first time on appeal. “[T]he general rule that appellate arguments must first be raised in the trial court applies to CINA and termination of parental rights cases.” In re A.B., 815 N.W.2d 764, 773 (Iowa 2012); accord In re K.C., 660 N.W.2d 29, 38 (Iowa 2003) (“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.”); Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctr

2017“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[O]ne purpose of our error preservation rules is to ensure that the opposing party and the district court are alerted to an issue at a time when corrective action can be taken or another alternative pursued.” Top of Iowa Coop. v. Sime Farms, Inc., 608 N.W.2d 454, 470 (Iowa 2000); see also Office of Consumer Advocate v. Iowa State Commerce Comm’n, 465 N.W.2d 280, 283 (Iowa 1991).

2017“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[O]ne purpose of our error preservation rules is to ensure that the opposing party and the district court are alerted to an issue at a time when corrective action can be taken or another alternative pursued.” Top of Iowa Coop. v. Sime Farms, Inc., 608 N.W.2d 454, 470 (Iowa 2000); see also Office of Consumer Advocate v. Iowa State Commerce Comm’n, 465 N.W.2d 280, 283 (Iowa 1991).

2012“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[I]t is not a sensible exercise of appellate review to analyze facts of an issue ‘without the benefit of a full record or lower court determination[ ].’ ” Id. (quoting Yee v. City of Escondido, 503 U.S. 519, 538 , 112 S.Ct. 1522, 1534 , 118 L.Ed.2d 153, 172 (1992)).

2012“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[I]t is not a sensible exercise of appellate review to analyze facts of an issue ‘without the benefit of a full record or lower court determination[ ].’ ” Id. (quoting Yee v. City of Escondido, 503 U.S. 519, 538 , 112 S.Ct. 1522, 1534 , 118 L.Ed.2d 153, 172 (1992)).

2025See Sandoval v. State, 975 N.W.2d 434 , 438 (Iowa 2022); Goode v. State, 920 N.W.2d 520, 526 (Iowa 2018) (“As a general rule, we do not address issues presented on appeal for the first 3 time . . . .”); Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (quoting Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002))).

2023See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also Goode v. State, 920 N.W.2d at 526 (“As a general rule, we do not address issues presented on appeal for the first time, and we do not remand cases to the district court for evidence on issues not raised and decided by the district court.”). 4.

2017See State v. Derby, 800 N.W.2d 52, 60 (Iowa 2011) (“Issues not raised before the district court, including constitutional issues, cannot be raised for the first time on appeal.” (citation omitted)); Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”). 3 court dismissed Boss’s second PCR application as being barred by the statute of limitations because he filed the application more than three years after the writ of procedendo.

2017See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also State v. Derby, 800 N.W.2d 52 , 60 5 (Iowa 2011) (“Issues not raised before the district court, including constitutional issues, cannot be raised for the first time on appeal.” (citation omitted)).

2007Co., 492 N.W.2d 399, 401 (Iowa 1992))).

2007Co., 492 N.W.2d 399, 401 (Iowa 1992))). 9 v. City of Iowa City, 703 N.W.2d 180, 184 (Iowa 2005) (quoting Iowa R.

2026See, e.g., State v. Treptow, 960 N.W.2d 98 , 109 (Iowa 2021) (“We have repeatedly rejected plain error review and will not adopt it now.”); Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); State v. Rutledge, 600 N.W.2d 324, 326 (Iowa 1999) (“[S]imple justice demands rigid adherence to the [error-preservation] rule.”).

2020“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002); see also State v. Rutledge, 600 N.W.2d 324, 325 (Iowa 1999) (“Nothing is more basic in the law of appeal and error than the axiom that a party cannot sing a song to us that was not first sung in trial court.”).

2023“The reasonable efforts concept would broadly include a visitation arrangement designed to facilitate reunification while protecting the child from the harm responsible for the removal.” In re L.M., 904 N.W.2d 835, 839 (Iowa 2017) (citation omitted).

2023See id. (requiring a parent to make an affirmative objection to the services offered when challenging the State’s reasonable efforts); see also Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”).

2023The mother asserts on appeal the department failed to provide reasonable efforts by not increasing visitation or move visitation to her residence after an August 24 home visit. 5“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). 7 Reasonable efforts “covers both the efforts to prevent and eliminate the need for removal.” In re C.B., 611 N.W.2d 489, 493 (Iowa 2000).

2023The State is not required to pursue “all means necessary.” Rather, reasonable efforts include “visitation designed to facilitate reunification while providing adequate protection for the child.” In re C.B., 611 N.W.2d 489, 493 (Iowa 2000) (emphasis added).

2022After all, we are “a court of review, not of first view.” Plowman v. Fort Madison Cmty. Hosp., 896 N.W.2d 393, 413 (Iowa 2017) (quoting Cutter v. Wilkinson, 544 U.S. 709 , 718 n.7 (2005)).

2021See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also Plowman v. Fort Madison Cmty. Hosp., 896 N.W.2d 393, 413 (noting appellate courts are courts of review, not first view).

2021Ct., 828 N.W.2d 309, 322 (Iowa 2013) (“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.”).

2019Ct., 828 N.W.2d 309, 322 (Iowa 2013) (“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.”).7 7 We also note our prior holdings that equitable tolling does not apply to section 822.3.

2021However, “a party receiving a preliminary ruling that does not unequivocally decide an issue must do more to 15 preserve the issue for appellate review.” UE Local 893/IUP v. State, 928 N.W.2d 51, 61 (Iowa 2019).

2021“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” This doctrine is based on the principle that “[i]t is not a sensible exercise of appellate review to analyze facts of an issue ‘without the benefit of a full record or lower court determination[].’ ” UE Loc. 893/IUP v. State, 928 N.W.2d 51, 60 (Iowa 2019) (alterations in original) (citation omitted) (quoting Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002)).

2021This applies “with equal force to constitutional issues.” In re Det. of Matlock, 860 N.W.2d 898, 910 (Iowa 2015) (Zager, J., concurring in part and dissenting in part).

2015“Our error preservation rules apply with equal force to constitutional issues.” In re Det. of Matlock, 860 N.W.2d 898, 910 (Iowa 2015).

2017“Error preservation does not turn, however, on the thoroughness of counsel’s research and briefing so long as the nature of the error has been timely brought to the attention of the district court.” Summy v. City of Des Moines, 708 N.W.2d 333, 338 (Iowa 2006), overruled in part on other grounds by Alcala v. Marriott Int’l, Inc., 880 N.W.2d 699 , 708 n.3 (Iowa 2016).

2017“Error preservation does not turn, however, on the thoroughness of counsel’s research and briefing so long as the nature of the error has been timely brought to the attention of the district court.” Summy v. City of Des Moines, 708 N.W.2d 333, 338 (Iowa 2006), overruled in part on other grounds by Alcala v. Marriott Int’l, Inc., 880 N.W.2d 699 , 708 n.3 (Iowa 2016).

2017See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also In re K.C., 660 N.W.2d at 38 (“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.”).

2017See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”); see also In re K.C., 660 N.W.2d at 38 (“Even issues implicating constitutional rights must be presented to and ruled upon by the district court in order to preserve error for appeal.”).

2017“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[O]ne purpose of our error preservation rules is to ensure that the opposing party and the district court are alerted to an issue at a time when corrective action can be taken or another alternative pursued.” Top of Iowa Coop. v. Sime Farms, Inc., 608 N.W.2d 454, 470 (Iowa 2000); see also Office of Consumer Advocate v. Iowa State Commerce Comm’n, 465 N.W.2d 280, 283 (Iowa 1991).

2017“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). “[O]ne purpose of our error preservation rules is to ensure that the opposing party and the district court are alerted to an issue at a time when corrective action can be taken or another alternative pursued.” Top of Iowa Coop. v. Sime Farms, Inc., 608 N.W.2d 454, 470 (Iowa 2000); see also Office of Consumer Advocate v. Iowa State Commerce Comm’n, 465 N.W.2d 280, 283 (Iowa 1991).

2017Inc., 880 N.W.2d 212, 217 (Iowa 2016).

2017Inc., 880 N.W.2d 212, 217 (Iowa 2016).

2026And “[t]he district court has broad discretion in ruling on a motion for new trial.” State v. Reeves, 670 N.W.2d 199, 202 (Iowa 2003).

2026See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”). 6 Even had he preserved error, the exceptions to termination “are permissive, not mandatory.” A.S., 906 N.W.2d at 475 (quoting In re A.M., 843 N.W.2d 100, 113 (Iowa 2014)).