field inquiry (Iowa) · Go Syfert
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field inquiry in Iowa

18 Iowa opinions name it 2 courts 1899–2025 5 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 (11)

CaseFollowedCited
State v. Mitchellgreen
iowa · 2003 · cited in 4 Iowa opinions naming this issue, 2008–2024
2 sentences

2024We agree with the district court that such evidence would have opened the door to questions from the prosecution that would comment on Collins’s right to counsel. “[O]pening the door” . . . pertains to the ability of a party to rebut inadmissible evidence offered by an adversary and provides that “one who induces a trial court to let down the bars to a field of inquiry 4 that is not competent or relevant to the issues cannot complain if his adversary is also allowed to avail himself of the opening.” State v. Parker, 747 N.W.2d 196, 206 (Iowa 2008) (quoting State v. Mitchell, 670 N.W.2d 416, 42

2024We agree with the district court that such evidence would have opened the door to questions from the prosecution that would comment on Collins’s right to counsel. “[O]pening the door” . . . pertains to the ability of a party to rebut inadmissible evidence offered by an adversary and provides that “one who induces a trial court to let down the bars to a field of inquiry 4 that is not competent or relevant to the issues cannot complain if his adversary is also allowed to avail himself of the opening.” State v. Parker, 747 N.W.2d 196, 206 (Iowa 2008) (quoting State v. Mitchell, 670 N.W.2d 416, 42

44
State v. Parkergreen
iowa · 2008 · cited in 4 Iowa opinions naming this issue, 2014–2024
2 sentences

2024This rule pertains to the ability of a party to rebut inadmissible evidence offered by an adversary and provides that “one who induces a trial court to let down the bars to a field of inquiry that is not competent or relevant to the issues cannot complain if his adversary is also allowed to avail himself of the opening.” State v. Parker, 747 N.W.2d 196, 206 (Iowa 2008) (quoting State v. Mitchell, 670 N.W.2d 416, 420 (Iowa 2003)).

2024We agree with the district court that such evidence would have opened the door to questions from the prosecution that would comment on Collins’s right to counsel. “[O]pening the door” . . . pertains to the ability of a party to rebut inadmissible evidence offered by an adversary and provides that “one who induces a trial court to let down the bars to a field of inquiry 4 that is not competent or relevant to the issues cannot complain if his adversary is also allowed to avail himself of the opening.” State v. Parker, 747 N.W.2d 196, 206 (Iowa 2008) (quoting State v. Mitchell, 670 N.W.2d 416, 42

34
State v. Paytongreen
iowa · 1992 · cited in 2 Iowa opinions naming this issue, 1993–2003
2 sentences

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

1993State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992) (“rule is well settled that one who induces the trial court to ‘let down the bars’ to a field of inquiry cannot complain if an adversary takes advantage of the same opening”).

22
State v. Oldfathergreen
iowa · 1981 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025DCI Laboratory testing later confirmed the field test results. 6 interpretation—whether the terms of the statute are broad enough to cover the actions of the accused, see State v. Oldfather, 306 N.W.2d 760, 763 (Iowa 1981)— our review is for errors at law.

11
People v. Hagberggreen
ill · 2000 · cited in 1 Iowa opinions naming this issue, 2018–2018
1 sentence

2018See, e.g., People v. Hagberg, 733 N.E.2d 1271, 1273 (Ill. 2000) (noting evidence is insufficient when “the officer testified that the field test could show only that the substance ‘might be’ narcotics” (citing People v. Judkins, 192 N.E.2d 848 (Ill. 1963))); but see id. (“[T]his court has never held that a field test is insufficient to identify the substance as a narcotic simply because the test was a field test.”).

11
The PEOPLE v. Judkinsgreen
ill · 1963 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., People v. Hagberg, 733 N.E.2d 1271, 1273 (Ill. 2000) (noting evidence is insufficient when “the officer testified that the field test could show only that the substance ‘might be’ narcotics” (citing People v. Judkins, 192 N.E.2d 848 (Ill. 1963))); but see id. (“[T]his court has never held that a field test is insufficient to identify the substance as a narcotic simply because the test was a field test.”).

2018See, e.g., People v. Hagberg, 733 N.E.2d 1271, 1273 (Ill. 2000) (noting evidence is insufficient when “the officer testified that the field test could show only that the substance ‘might be’ narcotics” (citing People v. Judkins, 192 N.E.2d 848 (Ill. 1963))); but see id. (“[T]his court has never held that a field test is insufficient to identify the substance as a narcotic simply because the test was a field test.”).

11
State v. Finnigangreen
iowa · 1991 · cited in 1 Iowa opinions naming this issue, 2003–2003
1 sentence

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

11
Warren Live Stock Co. v. Farrgreen
ca8 · 1905 · cited in 1 Iowa opinions naming this issue, 2003–2003
1 sentence

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

11
State v. Spilgergreen
iowa · 1993 · cited in 1 Iowa opinions naming this issue, 2003–2003
1 sentence

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

11
State v. Jonesgreen
iowa · 1991 · cited in 1 Iowa opinions naming this issue, 2003–2003
1 sentence

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

11
Spaulding v. Chicago, St. Paul & Kansas City Railway Co.green
iowa · 1896 · cited in 1 Iowa opinions naming this issue, 1899–1899
1 sentence

1899See Spaulding v. Railway Co., 98 Iowa, 205 , and cases cited; 2 Enc.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
The PEOPLE v. Judkinsgreen
ill · 1963 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., People v. Hagberg, 733 N.E.2d 1271, 1273 (Ill. 2000) (noting evidence is insufficient when “the officer testified that the field test could show only that the substance ‘might be’ narcotics” (citing People v. Judkins, 192 N.E.2d 848 (Ill. 1963))); but see id. (“[T]his court has never held that a field test is insufficient to identify the substance as a narcotic simply because the test was a field test.”).

2018See, e.g., People v. Hagberg, 733 N.E.2d 1271, 1273 (Ill. 2000) (noting evidence is insufficient when “the officer testified that the field test could show only that the substance ‘might be’ narcotics” (citing People v. Judkins, 192 N.E.2d 848 (Ill. 1963))); but see id. (“[T]his court has never held that a field test is insufficient to identify the substance as a narcotic simply because the test was a field test.”).

11

Also cited on this issue (11)

CaseCitedYears
State of Iowa v. Robin Eugene Brubaker green
iowa · 2011
1 sentence

2025And she suggests that the 11 substance could have been “legal hemp, which is virtually impossible to distinguish from marijuana through visual inspection.” To support her argument, Randel cites State v. Brubaker, 805 N.W.2d 164 (Iowa 2011), abrogated on other grounds by Crawford, 972 N.W.2d at 197–98.

12025–2025
United States v. Jacobsen green
scotus · 1984
1 sentence

2014The Court also found the field test was not a search as the action did not infringe “any constitutionally protected privacy interest that had not already been frustrated as the result of private conduct.” Id. at 126 .

12014–2014
State v. Williams green
iowa · 1923
1 sentence

2003Strong, et al., McCormick on Evidence § 57, at 253 (5th ed. 1999) (quoting Warren Live Stock Co. v. Farr, 142 F. 116, 117 (8th Cir.1905)); see also State v. Spilger, 508 N.W.2d 650, 652 (Iowa 1993); State v. Payton, 481 N.W.2d 325, 328 (Iowa 1992); State v. Finnigan, 478 N.W.2d 630, 631-32 (Iowa 1991); State v. Jones, 471 N.W.2d 833, 835-36 (Iowa 1991); State v. Williams, 195 Iowa 785, 796-98 , 192 N.W. 901 , 906-07 (1923).

12003–2003
McGrath v. Burkhard green
calctapp · 1955
2 sentences

1983They alleged the duties were unreasonable because “in the nature of police work, unprofessional, and foreign to the field of instruction.” They argued they had no training for the duties and the assignment was “degrading, humiliating and unprofessional.” Id. at 374-75 , 280 P.2d at 869-70 .

1983They alleged the duties were unreasonable because “in the nature of police work, unprofessional, and foreign to the field of instruction.” They argued they had no training for the duties and the assignment was “degrading, humiliating and unprofessional.” Id. at 374-75 , 280 P.2d at 869-70 .

11983–1983
State v. Johnson neutral
iowa · 1968
2 sentences

1970State v. Johnson (1968), Iowa, 155 N.W.2d 512, 515-516 , and citations.

1970State v. Johnson (1968), Iowa, 155 N.W.2d 512, 515-516 , and citations.

11970–1970
State v. Desmond green
iowa · 1899
1 sentence

1927In support of its contention, the State relies upon the following authorities’: State v. Desmond, 109 Iowa 72 ; State v. Sheets, 127 Iowa 73 ; and State v. O’Connell, 144 Iowa 559 .

11927–1927
State v. Sheets neutral
iowa · 1905
1 sentence

1927In support of its contention, the State relies upon the following authorities’: State v. Desmond, 109 Iowa 72 ; State v. Sheets, 127 Iowa 73 ; and State v. O’Connell, 144 Iowa 559 .

11927–1927
State v. Vance green
iowa · 1903
1 sentence

1927The scope of the exception is stated in State v. Vance, 119 Iowa 685 .

11927–1927
State v. O'Connell green
iowa · 1909
1 sentence

1927In support of its contention, the State relies upon the following authorities’: State v. Desmond, 109 Iowa 72 ; State v. Sheets, 127 Iowa 73 ; and State v. O’Connell, 144 Iowa 559 .

11927–1927
Westcott v. Meeker green
iowa · 1909
1 sentence

1912The question was fully examined in the late case of Westcott v. Meeker, 144 Iowa, 311 , and we there held, following the Massachusetts court, that: The rule for the' construction of wills followed by courts in recent times is to ascertain the intent of the tes tator from the whole instrument, attributing due weight to all its language, and then give effect to that intent unless prevented by some positive rule of law, rather than to try to make the interpretation of particular words or phrases in one instrument square with that before given to somewhat similar words used by some one else under

11912–1912
Ware Cattle Co. v. Anderson & Co. neutral
iowa · 1899
1 sentence

1903Ware Co. v. Anderson, 107 Iowa, 231 , and authorities cited.

11903–1903

Statutes the citing opinions construe

IA § Iowa Code § 124.401 (3) IA § Iowa Code § 814.7 (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

NJ 124 (1918–2026) CT 93 (1896–2022) IL 52 (1942–2025) NY 44 (1902–2026) TX 40 (1977–2026) CA 30 (1903–2020) PA 23 (1924–2026) MA 21 (1911–2025) IN 20 (1916–2025) IA 18 (1899–2025) FL 17 (2000–2017) NM 17 (1978–2025) DC 17 (1955–2022) GA 16 (1985–2024) WA 14 (1946–2024) WY 13 (1922–2018) KS 12 (1889–2004) MD 12 (1957–2007) MO 11 (1887–2025) AL 10 (1926–2017) NC 10 (1918–2018) OR 10 (1928–2025) OK 9 (1931–2004) MI 8 (1907–2022) OH 8 (1950–2021) MN 7 (1938–2024) ND 7 (1973–2021) TN 7 (1979–2026) UT 7 (1906–2025) LA 6 (1977–2014) WI 6 (1978–2026) VA 6 (1939–2022) KY 5 (1938–2026) AZ 5 (1982–2023) DE 5 (1940–2021) MS 5 (1970–2025) ID 4 (1983–2018) ME 3 (1879–1983) CO 3 (1981–2026) SC 3 (1955–2021) MT 3 (1909–2020) WV 2 (1978–2006) RI 2 (1983–1984) GU 2 (1978–2022) VT 2 (2009–2015) NV 2 (2015–2015)

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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