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18 Iowa opinions name it 2 courts 1994–2026 1 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.
| Case | Followed | Cited |
|---|---|---|
State v. Knousgreen2 sentences2017See Knous, 313 N.W.2d at 512 . 2017See Knous, 313 N.W.2d at 512 . | 3 | 3 |
United States v. Bassignanigreen2 sentences2016United States v. Bassignani, 575 F.3d 879, 885 (9th Cir. 2009) (discussing the difference between confrontational and nonconfrontational interrogation). 49 Here, there is no question the interrogation began in a low-key, matter-of-fact manner. 2016United States v. Bassignani, 575 F.3d 879, 885 (9th Cir.2009) (discussing the difference between confrontational and nonconfronta-tional interrogation). | 3 | 3 |
Gerst v. Marshallgreen2 sentences2009We noted in Gerst, 549 N.W.2d at 817 , but did not decide the question whether the substantial factor test should be eliminated. 2009The scope-of-liability issue is fact-intensive as it requires consideration of the risks that made the actor’s conduct tortious and a determination of whether the harm at issue is a result of any of those 4We noted in Gerst, 549 N.W.2d at 817 , but did not decide the question whether the substantial factor test should be eliminated. 15 risks. | 1 | 2 |
In Re the Marriage of Alesgreen1 sentence2026Similarly, Kimberlee’s cohabitation and the financial support she receives from her significant may be considered, see In re Marriage of Ales, 592 N.W.2d 698, 703 (Iowa Ct. App. 1999), although it is not a significant factor in our analysis. | 1 | 1 |
In Re the Marriage of Kunkelgreen1 sentence2015In re Marriage of Kunkel, 555 N.W.2d 250, 253 (Iowa Ct. App. 1996). | 1 | 1 |
Gibson v. Trantgreen1 sentence2003See Brewer v. Hagemann, 771 A.2d 1030, 1033-34 (Me.2001); Krahn v. Kinney, 43 Ohio St.3d 103 , 538 N.E.2d 1058, 1062 (1989); Gibson v. Trant, 58 S.W.3d 103, 111-12 (Tenn.2001); see also Schlumm v. Terrence J. | 1 | 1 |
Brewer v. Hagemanngreen1 sentence2003See Brewer v. Hagemann, 771 A.2d 1030, 1033-34 (Me.2001); Krahn v. Kinney, 43 Ohio St.3d 103 , 538 N.E.2d 1058, 1062 (1989); Gibson v. Trant, 58 S.W.3d 103, 111-12 (Tenn.2001); see also Schlumm v. Terrence J. | 1 | 1 |
Krahn v. Kinneygreen2 sentences2003See Brewer v. Hagemann, 771 A.2d 1030, 1033-34 (Me.2001); Krahn v. Kinney, 43 Ohio St.3d 103 , 538 N.E.2d 1058, 1062 (1989); Gibson v. Trant, 58 S.W.3d 103, 111-12 (Tenn.2001); see also Schlumm v. Terrence J. 2003See Brewer v. Hagemann, 771 A.2d 1030, 1033-34 (Me.2001); Krahn v. Kinney, 43 Ohio St.3d 103 , 538 N.E.2d 1058, 1062 (1989); Gibson v. Trant, 58 S.W.3d 103, 111-12 (Tenn.2001); see also Schlumm v. Terrence J. | 1 | 1 |
Solem v. Helmred1 sentence1999See id. at 743-44 (rejecting the defendant’s request that an individualized assessment of the severity of *62 the punishment be made). | 1 | 1 |
State v. Laffeygreen1 sentence1999See Laffey, 600 N.W.2d at 61 . | 1 | 1 |
State v. Ayersgreen1 sentence1997We have previously stated that in determining whether conduct meets the substantial factor test, we look to the “proximity and foreseeability of the harm flowing from the actor’s conduct, although it is not necessary that the actual consequences of a defendant’s negligence should have been foreseen.” Kelly, 476 N.W.2d at 349 ; State v. Ayers, 478 N.W.2d 606, 608 (Iowa 1991) (“Proximate cause is based on foreseeability.”); see also Restatement (Second) of Torts §§ 433, 435 (1965). | 1 | 1 |
Vincent Ex Rel. Staton v. Fairbanks Memorial Hospitalgreen1 sentence1996Miller, The Test of Factual Causation in Negligence and Strict Liability Cases 16 n.8, 130-34 (1961) (criticizing assertion that Restatement’s substantial factor test is confined to actual causation); Wright Article at 1781-83 (“the question of limiting liability due to the extent of contribution, rather than due to the absence of any contribution, is clearly a proximate-cause issue of policy or principle, rather than an issue of actual causation (contribution to the injury)”); see Vincent v. Fairbanks Memorial Hosp., 862 P.2d 847 , 851 n.7 (Alaska 1993) (observing the Restatement’s substantia | 1 | 1 |
Young v. Flathead Countygreen2 sentences1996See McDowell v. Davis, 104 Ariz. 69 , 448 P.2d 869, 871 (1968) (en banc) (rejecting use of substantial factor test because “it is a source of additional confusion injected into an already difficult area of law”); Young v. Flathead County, 232 Mont. 274, 757 P.2d 772, 777 (1988) (using but-for test for causation in fact and substantial factor test for those “rare circumstances” where concurrent causes would each have been sufficient to produce the .same result). 1996See McDowell v. Davis, 104 Ariz. 69 , 448 P.2d 869, 871 (1968) (en banc) (rejecting use of substantial factor test because “it is a source of additional confusion injected into an already difficult area of law”); Young v. Flathead County, 232 Mont. 274, 757 P.2d 772, 777 (1988) (using but-for test for causation in fact and substantial factor test for those “rare circumstances” where concurrent causes would each have been sufficient to produce the .same result). | 1 | 1 |
McDowell v. Davisgreen2 sentences1996See McDowell v. Davis, 104 Ariz. 69 , 448 P.2d 869, 871 (1968) (en banc) (rejecting use of substantial factor test because “it is a source of additional confusion injected into an already difficult area of law”); Young v. Flathead County, 232 Mont. 274, 757 P.2d 772, 777 (1988) (using but-for test for causation in fact and substantial factor test for those “rare circumstances” where concurrent causes would each have been sufficient to produce the .same result). 1996See McDowell v. Davis, 104 Ariz. 69 , 448 P.2d 869, 871 (1968) (en banc) (rejecting use of substantial factor test because “it is a source of additional confusion injected into an already difficult area of law”); Young v. Flathead County, 232 Mont. 274, 757 P.2d 772, 777 (1988) (using but-for test for causation in fact and substantial factor test for those “rare circumstances” where concurrent causes would each have been sufficient to produce the .same result). | 1 | 1 |
John P. Collins v. American Optometric Associationgreen1 sentence1996Miller, The Test of Factual Causation in Negligence and Strict Liability Cases 16 n.8, 130-34 (1961) (criticizing assertion that Restatement’s substantial factor test is confined to actual causation); Wright Article at 1781-83 (“the question of limiting liability due to the extent of contribution, rather than due to the absence of any contribution, is clearly a proximate-cause issue of policy or principle, rather than an issue of actual causation (contribution to the injury)”); see Vincent v. Fairbanks Memorial Hosp., 862 P.2d 847 , 851 n.7 (Alaska 1993) (observing the Restatement’s substantia | 1 | 1 |
Frederick v. Goffgreen2 sentences1996See Frederick, 251 Iowa at 298 , 100 N.W.2d at 629 ("We have used ... language quite similar to [the Restatement].... 1996See Frederick, 251 Iowa at 298 , 100 N.W.2d at 629 ("We have used ... language quite similar to [the Restatement].... | 1 | 1 |
Beeman v. Manville Corp. Asbestos Disease Compensation Fundgreen1 sentence1994See Beeman, 496 N.W.2d at 254 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Kelly v. Sinclair Oil Corp.
green
2 sentences1997We have previously stated that in determining whether conduct meets the substantial factor test, we look to the “proximity and foreseeability of the harm flowing from the actor’s conduct, although it is not necessary that the actual consequences of a defendant’s negligence should have been foreseen.” Kelly, 476 N.W.2d at 349 ; State v. Ayers, 478 N.W.2d 606, 608 (Iowa 1991) (“Proximate cause is based on foreseeability.”); see also Restatement (Second) of Torts §§ 433, 435 (1965). 1996Id. | 2 | 1996–1997 |
Tina Haskenhoff v. Homeland Energy Solutions, LLC
green
1 sentence2018Id. at 634–35 (Appel, J., specially concurring). | 1 | 2018–2018 |
Spaur v. Owens-Corning Fiberglas Corp.
green
1 sentence1997Id. | 1 | 1997–1997 |
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.
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.