three-factor test (Iowa) · Go Syfert
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three-factor test in Iowa

14 Iowa opinions name it 2 courts 1984–2024 2 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 (10)

CaseFollowedCited
Solem v. Helmred
scotus · 1983 · cited in 3 Iowa opinions naming this issue, 1984–2014
2 sentences

1999August claims we must apply the three-factor test set out in Solem v. Helm, 463 U.S. 277 , 103 S.Ct. 3001 , 77 L.Ed.2d 637 (1983), to determine whether his sentence violates the Eighth Amendment.

1999August claims we must apply the three-factor test set out in Solem v. Helm, 463 U.S. 277 , 103 S.Ct. 3001 , 77 L.Ed.2d 637 (1983), to determine whether his sentence violates the Eighth Amendment.

23
McMurry v. Eckertgreen
ky · 1992 · cited in 2 Iowa opinions naming this issue, 2024–2024
2 sentences

2024App. Ct. 2021) (adopting the Shelton test); McMurry v. Eckert, 833 S.W.2d 828, 830 (Ky. 1992) (“In our view, [Shelton and Hickman, 329 U.S. at 512–13,] address this issue appropriately and provide the proper standard.”); Club Vista Fin.

2024App. Ct. 2021) (adopting the Shelton test); McMurry v. Eckert, 833 S.W.2d 828, 830 (Ky. 1992) (“In our view, [Shelton and Hickman, 329 U.S. at 512–13,] address this issue appropriately and provide the proper standard.”); Club Vista Fin.

22
Airy's Inc. v. Hillgreen
illappct · 2021 · cited in 2 Iowa opinions naming this issue, 2024–2024
2 sentences

2024Ct. App. 2018) (“Where the deposition of opposing counsel is at issue, the party seeking such a deposition has the burden of meeting the three-factor test outlined in [Shelton].”); Airy’s, Inc. v. Hill, 193 N.E.3d 107, 111 (Ill.

2024Ct. App. 2018) (“Where the deposition of opposing counsel is it issue, the party seeking such a deposition has the burden of meeting the three-factor test outlined in [Shelton].”); Airy’s, Inc. v. Hill, 193 N.E.3d 107, 111 (Ill.

22
Sanford v. Manternachgreen
iowa · 1999 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009In Sanford v. Manternach, 601 N.W.2d 360, 364 (Iowa 1999), we declared that a liberty interest in accrued credits is created by Iowa’s law providing for earned-time credits.

2009In Sanford v. Manternach, 601 N.W.2d 360, 364 (Iowa 1999), we declared that a liberty interest in accrued credits is created by Iowa’s law providing for earned- time credits.

22
State v. Richgreen
iowa · 1981 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016Moreover our court has previously concluded the supreme court did not announce a new rule in Robinson but rather only clarified existing law by its reliance upon the three-factor test announced in State v. Rich, 305 N.W.2d 739, 741-42 (Iowa 1981).

11
State v. Jonesgreen
iowa · 2003 · cited in 1 Iowa opinions naming this issue, 2015–2015
2 sentences

2015Id. at 146.

2015Id. at 146 .

11
State of Iowa v. Charles James David Olivergreen
iowa · 2012 · cited in 1 Iowa opinions naming this issue, 2014–2014
1 sentence

2014State v. Oliver, 812 N.W.2d 636, 647 (Iowa 2012) (citing Solem v. Helm, 463 U.S. 277, 292 , 103 S. Ct. 3001, 3011 , 77 L.

11
Tragarz v. Keene Corporationgreen
ca7 · 1993 · cited in 1 Iowa opinions naming this issue, 1994–1994
1 sentence

1994See Tragarz v. Keene Corp., 980 F.2d 411, 420-21 (7th Cir.1992) (application of the three prongs may vary under different circumstances).

11
State v. Williamsgreen
iowa · 1979 · cited in 1 Iowa opinions naming this issue, 1989–1989
2 sentences

1989Under the three-factor analysis explained in State v. Williams, 285 N.W.2d 248, 267 (Iowa 1979), we find no abuse.

1989Under the three-factor analysis explained in State v. Williams, 285 N.W.2d 248, 267 (Iowa 1979), we find no abuse.

11
Chevron Oil Co. v. Husonred
scotus · 1971 · cited in 1 Iowa opinions naming this issue, 1989–1989
2 sentences

1989In Beeck , we examined the retrospective application of the Weitl parental consortium rule by applying a three-factor test derived from the United States Supreme Court in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349, 355 , 30 L.Ed.2d 296, 306 (1971) (test adopted to determine retroactivity).

1989In Beeck , we examined the retrospective application of the Weitl parental consortium rule by applying a three-factor test derived from the United States Supreme Court in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349, 355 , 30 L.Ed.2d 296, 306 (1971) (test adopted to determine retroactivity).

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
Hickman v. Taylor green
scotus · 1947
2 sentences

2024App. Ct. 2021) (adopting the Shelton test); McMurry v. Eckert, 833 S.W.2d 828, 830 (Ky. 1992) (“In our view, [Shelton and Hickman, 329 U.S. at 512–13,] address this issue appropriately and provide the proper standard.”); Club Vista Fin.

2024App. Ct. 2021) (adopting the Shelton test); McMurry v. Eckert, 833 S.W.2d 828, 830 (Ky. 1992) (“In our view, [Shelton and Hickman, 329 U.S. at 512–13,] address this issue appropriately and provide the proper standard.”); Club Vista Fin.

22024–2024
Bowers v. Polk County Board of Supervisors green
iowa · 2002
2 sentences

2009A procedure does not necessarily violate due process simply “ ‘ “because another method may seem fairer or wiser.” ’ ” Id. at 666 (quoting Bowers, 638 N.W.2d at 691 ). 12 To determine what process is due, the court undertakes a three factor analysis: “ ‘First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government’s interest, including the function involved and the fiscal and adminis

2009A procedure does not necessarily violate due process simply “ ‘ “because another method may seem fairer or wiser.” ’ ” Id. at 666 (quoting Bowers, 638 N.W.2d at 691 ). 12 To determine what process is due, the court undertakes a three factor analysis: “ ‘First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government’s interest, including the function involved and the fiscal and adminis

22009–2009
Beeck v. S.R. Smith Co. green
iowa · 1984
2 sentences

2019Id.

2019Id.

12019–2019
In RE the Detention of Paul Michael Blaise Paul Michael Blaise green
iowa · 2013
1 sentence

2015Based on the three-factor test found in Blaise, 830 N.W.2d at 319 , we conclude it would be inappropriate for us to engage in a sua sponte harmless- error review.

12015–2015

Statutes the citing opinions construe

IA § Iowa Code § 903A.2 (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

TX 97 (1972–2026) AL 73 (1978–2024) PA 57 (1982–2024) ID 44 (1980–2024) MI 43 (1976–2025) CA 43 (1965–2025) CO 36 (1984–2026) NJ 32 (1990–2026) IL 29 (1988–2025) MN 28 (1981–2025) WA 26 (2001–2024) NV 22 (2006–2022) NM 21 (1987–2026) WI 20 (1995–2024) KS 20 (1983–2022) VI 16 (2014–2025) IN 16 (1984–2025) OH 15 (1999–2025) GA 15 (1996–2023) IA 14 (1984–2024) LA 14 (1994–2026) MS 14 (1994–2025) MO 14 (1985–2021) MD 12 (1988–2026) HI 12 (1978–2025) WV 12 (1988–2023) MT 11 (1998–2024) CT 11 (1985–2021) AZ 11 (1986–2022) NY 11 (1994–2026) NH 10 (1996–2023) DE 10 (2015–2025) OR 10 (1982–2025) NC 9 (2015–2025) AR 9 (2004–2024) UT 8 (2004–2022) MA 8 (2000–2025) TN 7 (1999–2024) FL 7 (2001–2026) VT 5 (2000–2025) ME 4 (1989–2020) VA 4 (2002–2025) SC 4 (2009–2023) NE 4 (1991–2016) WY 3 (1992–2026) KY 3 (2018–2024) SD 3 (1997–2024) DC 3 (1983–2021) ND 2 (2016–2022) OK 2 (1999–2010) AK 2 (1996–2025)

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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