Graves standard (Iowa) · Go Syfert
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Graves standard in Iowa

14 Iowa opinions name it 2 courts 2002–2025 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 (9)

CaseFollowedCited
State v. Gravesgreen
iowa · 2003 · cited in 6 Iowa opinions naming this issue, 2014–2025
2 sentences

2021See State v. Krogmann, 804 N.W.2d 518, 526 (Iowa 2011) (concluding defendant failed to preserve claim of prosecutorial misconduct because, while he objected at the time, “[h]e objected only that the question was argumentative” and “asked for no further relief such as a mistrial”), see also State v. Graves, 668 N.W.2d 860, 868 (Iowa 2003) (“Because objection was not made at trial, Graves’ claim of prosecutorial misconduct is raised on appeal in the context of an ineffective-assistance-of-counsel claim.”).

2021In mentioning one of the Graves factors, curative measures, Robinson states, “[n]o curative action was taken as defense counsel breached a duty in failing to object.” See Graves, 668 N.W.2d at 869 .

46
State of Iowa v. Zyriah Henry Floyd Schlittergreen
iowa · 2016 · cited in 4 Iowa opinions naming this issue, 2016–2018
2 sentences

2018See State v. Graves, 668 N.W.2d 860, 869 (Iowa 2003); see also Schlitter, 881 N.W.2d at 394 (noting the Graves test “easily translate[s] to an evaluation of prosecutorial error”).

2018See State v. Graves, 668 N.W.2d 860, 869 (Iowa 2003); see also Schlitter, 881 N.W.2d at 394 (noting the Graves test “easily translate[s] to an evaluation of prosecutorial error”).

44
State v. Careygreen
iowa · 2006 · cited in 2 Iowa opinions naming this issue, 2019–2020
2 sentences

2020See Carey, 709 N.W.2d at 556 .

2019See Carey, 709 N.W.2d at 556 .

22
State v. Hilleshiemgreen
iowa · 1980 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022See, e.g., State v. Hilleshiem, 291 N.W.2d 314 , 318–19 (Iowa 1980) (listing requirements for “checkpoint” stop to meet constitutional muster when there is not consent, probable cause, or Terry-type reasonable and articulable suspicion).

11
Delaware v. Prousegreen
scotus · 1979 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022Cf. Delaware v. Prouse, 440 U.S. 648, 653 (1979) (“The Fourth and Fourteenth Amendments are implicated . . . because stopping an automobile and detaining its occupants constitutes a ‘seizure’ within the meaning of those Amendments, even though the purpose of the stop is limited and the resulting detention quite brief.”).

11
State of Iowa v. Robert Paul Krogmanngreen
iowa · 2011 · cited in 1 Iowa opinions naming this issue, 2021–2021
1 sentence

2021See State v. Krogmann, 804 N.W.2d 518, 526 (Iowa 2011) (concluding defendant failed to preserve claim of prosecutorial misconduct because, while he objected at the time, “[h]e objected only that the question was argumentative” and “asked for no further relief such as a mistrial”), see also State v. Graves, 668 N.W.2d 860, 868 (Iowa 2003) (“Because objection was not made at trial, Graves’ claim of prosecutorial misconduct is raised on appeal in the context of an ineffective-assistance-of-counsel claim.”).

11
State of Iowa v. Mark Gabriel Martingreen
iowa · 2016 · cited in 1 Iowa opinions naming this issue, 2016–2016
2 sentences

2016Ritenour argues the prosecutor’s characterization of her statements as “lies” was “not isolated but repeated several times throughout the course of the 5 Our supreme court recently explained its choice to use the term “error” rather than “misconduct” so as “to avoid automatically implying that the prosecutor violated our ethical rules.” State v. Martin, ___ N.W.2d ___, ___ n.2, 2016 WL 1533515, at *5 (Iowa 2016). 19 closing argument.” She also points out the State made her changing stories the central issue in the case.

2016Ritenour argues the prosecutor’s characterization of her statements as “lies” was “not isolated but repeated several times throughout the course of the 5 Our supreme court recently explained its choice to use the term “error” rather than “misconduct” so as “to avoid automatically implying that the prosecutor violated our ethical rules.” State v. Martin, ___ N.W.2d ___, ___ n.2, 2016 WL 1533515, at *5 (Iowa 2016). 19 closing argument.” She also points out the State made her changing stories the central issue in the case.

11
Strickland v. Washingtongreen
scotus · 1984 · cited in 1 Iowa opinions naming this issue, 2003–2003
2 sentences

2003See Strickland v. Washington, 466 U.S. 668, 689 , 104 S.Ct. 2052, 2065 , 80 L.Ed.2d 674, 693 (1984) (holding Sixth Amendment guarantees the effective assistance of counsel to ensure criminal defendants receive a fair trial).

2003See Strickland v. Washington, 466 U.S. 668, 689 , 104 S.Ct. 2052, 2065 , 80 L.Ed.2d 674, 693 (1984) (holding Sixth Amendment guarantees the effective assistance of counsel to ensure criminal defendants receive a fair trial).

11
Lara v. Thomasgreen
iowa · 1994 · cited in 1 Iowa opinions naming this issue, 2002–2002
1 sentence

2002She contends the word “injure” should have been changed to “affect,” the word we used in Lara v. Thomas, 512 N.W.2d 777, 785 (Iowa 1994).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Statutes the citing opinions construe

IA § Iowa Code § 602.9206 (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

IA 14 (2002–2025) MS 5 (1993–2010) MO 4 (1942–2021) TX 4 (2008–2021) NJ 4 (1982–2024) IN 4 (2003–2015) GA 3 (2016–2018) CO 3 (2016–2016) PA 3 (1987–2017) FL 2 (2006–2022) CA 2 (1972–2021) MT 2 (1994–2007) VA 2 (2010–2017)

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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