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

19 Iowa opinions name it 2 courts 1960–2025 4 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 (16)

CaseFollowedCited
State v. Halliburtongreen
iowa · 1995 · cited in 2 Iowa opinions naming this issue, 2000–2017
2 sentences

2017See State v. Walker, 610 N.W.2d 524, 526 (Iowa 2000) (“An illegal sentence may be urged as a ground for reversal at any time, obviating the need to challenge the error in district court in order to preserve the issue for appeal.”); State v. Halliburton, 539 N.W.2d 339, 343 (Iowa 1995) (“[I]llegal sentences are not subject to the usual requirements of error preservation and waiver. . . . [Defendant’s] conduct in the trial court does not prevent him from claiming on appeal that his sentences violated section 701.9.”).

2000State v. Halliburton, 539 N.W.2d 339, 343 (Iowa 1995); State v. Stratton, 519 N.W.2d 403, 405 (Iowa 1994); State v. Austin, 503 N.W.2d 604, 607 (Iowa 1993).

22
State v. Shankgreen
iowa · 1980 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See State v. Shank, 296 N.W.2d 791, 792 (Iowa 1980).

2017See State v. Shank, 296 N.W.2d 791, 792 (Iowa 1980).

22
Hammond v. Florida Asset Financing Corp.green
iowa · 2005 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017Corp., 695 N.W.2d 1, 8 (Iowa 2005) (affirming dismissal of defendant for lack of personal jurisdiction and rejecting named plaintiffs’ argument jurisdiction was supported by claims of putative class members, noting “there has been no determination that a class exists or that the action may proceed as a class action”). 3 Because no class had been certified, Wellmark acknowledges putative class members in this civil action are not bound by the summary judgment under principles of res judicata.

2017Corp., 695 N.W.2d 1, 8 (Iowa 2005) (affirming dismissal of defendant for lack of personal jurisdiction and rejecting named plaintiffs’ argument jurisdiction was supported by claims of putative class members, noting “there has been no determination that a class exists or that the action may proceed as a class action”). 3 3Because of similarities between the Iowa and federal class-action rules, we may look to federal decisions for guidance.

22
State v. Reynoldsgreen
iowa · 2008 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025It is the impossibility of such recall that demonstrates the need for the exception.”); State v. Reynolds, 746 N.W.2d 837, 843 (Iowa 2008) (“[T]he specific person who created the record in the course of 11 business need not testify to lay the foundation for the business records exception . . . .”).

11
State of Iowa v. Wonetah Einfeldtgreen
iowa · 2018 · cited in 1 Iowa opinions naming this issue, 2021–2021
1 sentence

2021See State v. Einfeldt, 914 N.W.2d 773 , 783 n.3 (Iowa 2018) (“[E]ven the presence of mental illness at trial, in and of itself, is not necessarily sufficient to trigger the requirement of a competency hearing . . . .

11
Boze v. Stategreen
ind · 1987 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020LaFave et al., Criminal Procedure § 25.1(d), at 781 (4th ed. 2015) (footnotes omitted); see also Boze, 514 N.E.2d at 277–78 (remanding case to vacate conviction on lesser included battery charge after defendant was convicted of attempted murder).

11
State v. Dittmergreen
iowactapp · 2002 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017A merger argument is inapplicable where there are “two separate crimes.” Walker, 610 N.W.2d at 525 ; State v. Dittmer, 653 N.W.2d 774, 777-78 (Iowa Ct. App. 2002).

11
State v. Walkergreen
iowa · 2000 · cited in 1 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See State v. Walker, 610 N.W.2d 524, 526 (Iowa 2000) (“An illegal sentence may be urged as a ground for reversal at any time, obviating the need to challenge the error in district court in order to preserve the issue for appeal.”); State v. Halliburton, 539 N.W.2d 339, 343 (Iowa 1995) (“[I]llegal sentences are not subject to the usual requirements of error preservation and waiver. . . . [Defendant’s] conduct in the trial court does not prevent him from claiming on appeal that his sentences violated section 701.9.”).

2017A merger argument is inapplicable where there are “two separate crimes.” Walker, 610 N.W.2d at 525 ; State v. Dittmer, 653 N.W.2d 774, 777-78 (Iowa Ct. App. 2002).

11
Lynn G. Lamasters Vs. State of Iowagreen
iowa · 2012 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016See Lamasters, 821 N.W.2d at 862 . 5 “The hearing previously set for January 23, 2015, beginning at 9:00 a.m. is continued to begin that same day but beginning at 10:30 a.m.” Any surprise or lack of preparedness is not the result of the court’s order but rather is attributable to Hildreth.

11
State v. Petersengreen
iowa · 2004 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016See State v. Petersen, 678 N.W.2d 611, 613 (Iowa 2004).

11
State v. Austingreen
iowa · 1993 · cited in 1 Iowa opinions naming this issue, 2000–2000
1 sentence

2000State v. Halliburton, 539 N.W.2d 339, 343 (Iowa 1995); State v. Stratton, 519 N.W.2d 403, 405 (Iowa 1994); State v. Austin, 503 N.W.2d 604, 607 (Iowa 1993).

11
State v. Strattongreen
iowa · 1994 · cited in 1 Iowa opinions naming this issue, 2000–2000
1 sentence

2000State v. Halliburton, 539 N.W.2d 339, 343 (Iowa 1995); State v. Stratton, 519 N.W.2d 403, 405 (Iowa 1994); State v. Austin, 503 N.W.2d 604, 607 (Iowa 1993).

11
Moseley v. Ricksgreen
iowa · 1937 · cited in 1 Iowa opinions naming this issue, 1983–1983
2 sentences

1983See Moseley v. Ricks, 223 Iowa at 1040 , 274 N.W. at 24 (“[t]his principle [of immunity] seems so conducive to the proper administration of justice that we are not disposed to overrule it.”).

1983See Moseley v. Ricks, 223 Iowa at 1040 , 274 N.W. at 24 (“[t]his principle [of immunity] seems so conducive to the proper administration of justice that we are not disposed to overrule it.”).

11
Jones v. Wolfgreen
scotus · 1979 · cited in 1 Iowa opinions naming this issue, 1983–1983
2 sentences

1983Id at 605-06, 99 S.Ct. at 3026 , 61 L.Ed.2d at 785-86 (citations to the dissenting opinion omitted).

1983Id at 605-06, 99 S.Ct. at 3026 , 61 L.Ed.2d at 785-86 (citations to the dissenting opinion omitted).

11
State v. Shephardgreen
iowa · 1963 · cited in 1 Iowa opinions naming this issue, 1964–1964
2 sentences

1964State v. Shephard, 255 Iowa 1218, 1231 , 124 N.W.2d 712, 719, 720 .

1964State v. Shephard, 255 Iowa 1218, 1231 , 124 N.W.2d 712, 719, 720 .

11
Olson v. Neubauergreen
minn · 1941 · cited in 1 Iowa opinions naming this issue, 1960–1960
2 sentences

1960See as somewhat in point Olson v. Neubauer, 211 Minn. 218 , 300 N.W. 613, 614, 615 .

1960See as somewhat in point Olson v. Neubauer, 211 Minn. 218 , 300 N.W. 613, 614, 615 .

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 (4)

CaseCitedYears
State v. Tejeda green
iowa · 2004
2 sentences

2025But the supreme court further clarified that the question is whether the trial court was “apprised of a potential breakdown in communication” that constituted “a complete breakdown in communication between the attorney and the defendant.” Id. at 750–51 (citation omitted). 8 Although Sallis never directly requested substitute counsel, both he and defense counsel extensively described the alleged breakdown in communication and provided the district court with “a colorable complaint” alerting the district court of the need for an inquiry.

2025Id. at 751 .

12025–2025
State of Iowa v. Marshaun Jordan Merrett green
iowa · 2014
1 sentence

2024“Accepting such a waiver from a defendant is not so different from accepting a defendant’s guilty plea refusing to admit commission of a criminal act, but recognizing the record contains strong evidence of actual guilt.” State v. Merrett, No. 12-1336, 2013 WL 3855692 , at *12 (Iowa Ct. App. July 24, 2013) (Tabor, J., dissenting) (analyzing record where the district court notified the parties of potential inconsistency in a verdict but the parties declined to have the jury reconsider), vacated on other grounds, 842 N.W.2d 266 .

12024–2024
Imbler v. Pachtman green
scotus · 1976
2 sentences

1977Recently the United States Supreme Court has exhaustively detailed the policies behind adhering to the need for a rule of absolute prosecutorial immunity where the prosecutor’s activities are “intimately associated with the judicial phase of the criminal process.” Imbler v. Pachtman, 424 U.S. 409 , 96 S.Ct. 984 , 47 L.Ed.2d 128 (1976).

1977Recently the United States Supreme Court has exhaustively detailed the policies behind adhering to the need for a rule of absolute prosecutorial immunity where the prosecutor’s activities are “intimately associated with the judicial phase of the criminal process.” Imbler v. Pachtman, 424 U.S. 409 , 96 S.Ct. 984 , 47 L.Ed.2d 128 (1976).

11977–1977
United States v. Britton green
circtdma · 1822
1 sentence

1970The reasons were well stated by Justice Story in United States v. Britton (2 CCA, 1822), 2 Mason 464, 470-471 , 24 Fed.Cas. pp. 1239, 1241.

11970–1970

Statutes the citing opinions construe

IA § Iowa Code § 701.9 (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

NY 128 (1919–2026) CA 103 (1953–2025) TX 87 (1978–2025) IL 67 (1955–2025) OH 50 (1988–2026) LA 49 (1956–2023) NJ 49 (1960–2026) FL 45 (1973–2019) PA 43 (1951–2024) CT 35 (1973–2024) MI 30 (1970–2025) DC 29 (1978–2024) MA 29 (1895–2025) IN 24 (1976–2020) OR 23 (1985–2025) WA 22 (1944–2025) MO 21 (1982–2024) CO 21 (1984–2025) MD 19 (1988–2024) IA 19 (1960–2025) WI 18 (1975–2023) TN 16 (1978–2024) NM 15 (1980–2023) NC 14 (1982–2025) DE 13 (1990–2025) AZ 13 (1968–2024) KS 12 (1980–2025) ID 11 (1972–2021) MS 9 (1980–2017) WV 9 (1975–2017) VA 9 (1967–2013) AK 9 (1982–2025) NH 9 (1979–2018) AL 9 (1994–2016) GA 9 (1925–2025) RI 8 (1979–2010) SC 8 (2007–2011) ME 8 (1978–2025) MN 7 (1966–2024) UT 7 (1995–2022) KY 7 (1985–2025) HI 6 (2000–2020) WY 6 (1966–2006) VT 5 (1991–2018) OK 5 (1988–2023) NE 4 (1998–2022) NV 4 (2016–2017) MT 4 (1989–2015) AR 4 (1982–2020) SD 2 (2005–2025) ND 2 (1979–1983)

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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