residency requirement (Iowa) · Go Syfert
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residency requirement in Iowa

12 Iowa opinions name it 2 courts 1982–2024 3 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 (14)

CaseFollowedCited
Toomer v. Witsellgreen
scotus · 1948 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024As we explain, though, whether this particular residency requirement—falling far beyond the realm of domestic relations—is constitutional is not dictated by Sosna’s holding. 11 “considerable leeway in analyzing local evils and in prescribing appropriate cures.” United Bldg., 465 U.S. at 222–23 (quoting Toomer v. Witsell, 334 U.S. 385, 396 (1948)).

11
People v. Parkergreen
calctapp · 2006 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See Sosna v. Iowa, 419 U.S. 393 , 409– 10 (1975) (affirming one-year durational residency requirement for filing petition for dissolution of marriage); People v. Parker, 46 Cal. Rptr. 3d 888, 896 (Ct. App. 2006) (holding that five-year residency requirement for sex offender to file a petition for rehabilitation and pardon did not violate the privileges and immunities clause). 22 Doe v. State, 943 N.W.2d 608 , 610 (Iowa 2020) (“Any interpretive inquiry thus begins with the language of the statute at issue.”).

11
Sosna v. Iowagreen
scotus · 1975 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See Sosna v. Iowa, 419 U.S. 393 , 409– 10 (1975) (affirming one-year durational residency requirement for filing petition for dissolution of marriage); People v. Parker, 46 Cal. Rptr. 3d 888, 896 (Ct. App. 2006) (holding that five-year residency requirement for sex offender to file a petition for rehabilitation and pardon did not violate the privileges and immunities clause). 22 Doe v. State, 943 N.W.2d 608 , 610 (Iowa 2020) (“Any interpretive inquiry thus begins with the language of the statute at issue.”).

11
State v. Maciasgreen
arizctapp · 1989 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir. 1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 513 P.2d 935, 938 (Ariz. 1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 783 P.2d 255, 258 (Ariz. Ct. App. 1989) (noting a state constitutiona

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir.1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 109 Ariz. 506 , 513 P.2d 935, 938 (1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 162 Ariz. 316 , 783 P.2d 255, 258 (Ariz.Ct.App.1989) (noting

11
Snyder v. Boulwaregreen
mont · 1939 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Ct., 272 62 Cal. Rptr. 702 , 703–04 (Ct. App. 1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 96 P.2d 913, 915 (Mont. 1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar with the needs of the particular section of the county”); Gangemi v

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

11
Gangemi v. Rosengardgreen
nj · 1965 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Ct., 272 62 Cal. Rptr. 702 , 703–04 (Ct. App. 1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 96 P.2d 913, 915 (Mont. 1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar with the needs of the particular section of the county”); Gangemi v

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

11
Horwitz v. Reichensteingreen
nj · 1954 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Ct., 272 62 Cal. Rptr. 702 , 703–04 (Ct. App. 1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 96 P.2d 913, 915 (Mont. 1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar with the needs of the particular section of the county”); Gangemi v

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

11
Wall v. Municipal Courtgreen
calctapp · 1990 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

11
Wayne B. Woodward v. City of Deerfield Beach, a Municipal Corporation of the State of Floridagreen
ca5 · 1976 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir. 1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 513 P.2d 935, 938 (Ariz. 1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 783 P.2d 255, 258 (Ariz. Ct. App. 1989) (noting a state constitutiona

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir.1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 109 Ariz. 506 , 513 P.2d 935, 938 (1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 162 Ariz. 316 , 783 P.2d 255, 258 (Ariz.Ct.App.1989) (noting

11
Farnsworth v. Jonesgreen
ncctapp · 1994 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Ct., 272 62 Cal. Rptr. 702 , 703–04 (Ct. App. 1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 96 P.2d 913, 915 (Mont. 1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar with the needs of the particular section of the county”); Gangemi v

2014Ch, 223 Cal.App.3d 247 , 272 Cal.Rptr. 702, 703-04 (1990) (noting that “the possibility that citizen confidence in the adjudication of traffic cases increases when they are handled by local residents” was an important legislative goal that was sufficient to justify the requirement that traffic commissioners be residents of the county in which they are appointed); Snyder v. Boulware, 109 Mont. 427 , 96 P.2d 913, 915 (1939) (indicating the purpose of a residency requirement for county commissioners “was to disqualify those who were not familiar -with the needs of the particular section of the co

11
Triano v. Massiongreen
ariz · 1973 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir. 1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 513 P.2d 935, 938 (Ariz. 1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 783 P.2d 255, 258 (Ariz. Ct. App. 1989) (noting a state constitutiona

2014See, e.g., Woodward v. City of Deerfield Beach, 538 F.2d 1081, 1083 (5th Cir.1976) (noting durational residency requirements ensure “candidate knowledge of the issues and problems of the area”); Triano v. Massion, 109 Ariz. 506 , 513 P.2d 935, 938 (1973) (finding a residency requirement that candidates had to be qualified electors for six months was supported by the conclusion that candidates living in the districts they represent are likely to familiarize themselves with the people and the problems of the district); State v. Macias, 162 Ariz. 316 , 783 P.2d 255, 258 (Ariz.Ct.App.1989) (noting

11
J. D. Wright v. The City of Jackson, Mississippigreen
ca5 · 1975 · cited in 1 Iowa opinions naming this issue, 1991–1991
1 sentence

1991Andre v. Board of Trustees, 561 F.2d 48, 50 (7th Cir.1977) cert. denied, 434 U.S. 1013 , 98 S.Ct. 727 , 54 L.Ed.2d 756 (1978); Wright v. City of Jackson, 506 F.2d 900, 903 (5th Cir.1975).

11
Frank Andre v. Board of Trustees of the Village of Maywoodgreen
ca7 · 1977 · cited in 1 Iowa opinions naming this issue, 1991–1991
1 sentence

1991Andre v. Board of Trustees, 561 F.2d 48, 50 (7th Cir.1977) cert. denied, 434 U.S. 1013 , 98 S.Ct. 727 , 54 L.Ed.2d 756 (1978); Wright v. City of Jackson, 506 F.2d 900, 903 (5th Cir.1975).

11
In Re the Marriage of Bouskagreen
iowa · 1977 · cited in 1 Iowa opinions naming this issue, 1982–1982
1 sentence

1982In re Marriage of Bouska, 256 N.W.2d 196, 198 (Iowa 1977).

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 (12)

CaseCitedYears
State Ex Rel. Turner v. Scott green
iowa · 1978
2 sentences

2021Turner, 269 N.W.2d at 829–31.

2021Turner, 269 N.W.2d at 829–31.

22021–2021
United Building & Constr. Trades Council of Camden Cty. v. Mayor and Council of Camden green
scotus · 1984
1 sentence

2024As we explain, though, whether this particular residency requirement—falling far beyond the realm of domestic relations—is constitutional is not dictated by Sosna’s holding. 11 “considerable leeway in analyzing local evils and in prescribing appropriate cures.” United Bldg., 465 U.S. at 222–23 (quoting Toomer v. Witsell, 334 U.S. 385, 396 (1948)).

12024–2024
In Re the Marriage of Kimura green
iowa · 1991
1 sentence

2017In Kimura, our supreme court rejected a residency challenge to a 10 dissolution action brought by a Japanese citizen, noting “nothing in the evidence to support” the wife’s contention that her husband’s residence here was “in bad faith and only for the purpose of obtaining a dissolution of marriage.” Id. (acknowledging Iowa’s “liberal dissolution marriage law as compared to Japan’s” may have been “one reason” the husband moved to Iowa but concluding that fact was not sufficient to defeat a finding of residency).

12017–2017
Kollman v. McGregor green
iowa · 1949
2 sentences

2013We held the actual residency test applies under the general venue statute for personal actions, which expressly provides for venue where the defendant “actually resides.” Id. at 1332 , 39 N.W.2d at 303 (quoting Iowa Code § 616.17 ) (1946) (emphasis added).

2013We held the actual residency test applies under the general venue statute for personal actions, which expressly provides for venue where the defendant “actually resides.” Id. at 1332 , 39 N.W.2d at 303 (quoting Iowa Code § 616.17 ) (1946) (emphasis added).

12013–2013
Kroblin Refrigerated Xpress, Inc. v. Iowa Insurance Guaranty Ass'n green
iowa · 1990
1 sentence

2013Iowa Code chapter 236 does not define the term “resides” or “resident.” “When the term ‘resident’ is undefined in the statute, it becomes an ambiguous term requiring statutory construction to determine its legal meaning.” Kroblin, 461 N.W.2d at 177-78 .

12013–2013
Clinton Police Department Bargaining Unit v. City of Clinton green
iowa · 1991
1 sentence

2005Clinton Police Dep’t Bargaining Unit, 464 N.W.2d at 878 .

12005–2005
AMCO Insurance Co. v. Rossman green
iowa · 1994
1 sentence

1996Id.

11996–1996
Stone v. Export-Import Bank of the United States green
scotus · 1978
1 sentence

1991Andre v. Board of Trustees, 561 F.2d 48, 50 (7th Cir.1977) cert. denied, 434 U.S. 1013 , 98 S.Ct. 727 , 54 L.Ed.2d 756 (1978); Wright v. City of Jackson, 506 F.2d 900, 903 (5th Cir.1975).

11991–1991
Fouke Co. v. Animal Welfare Institute green
scotus · 1978
1 sentence

1991Andre v. Board of Trustees, 561 F.2d 48, 50 (7th Cir.1977) cert. denied, 434 U.S. 1013 , 98 S.Ct. 727 , 54 L.Ed.2d 756 (1978); Wright v. City of Jackson, 506 F.2d 900, 903 (5th Cir.1975).

11991–1991
Nizer v. Meeropol green
scotus · 1978
1 sentence

1991Andre v. Board of Trustees, 561 F.2d 48, 50 (7th Cir.1977) cert. denied, 434 U.S. 1013 , 98 S.Ct. 727 , 54 L.Ed.2d 756 (1978); Wright v. City of Jackson, 506 F.2d 900, 903 (5th Cir.1975).

11991–1991
Eastern Seaboard, Etc. v. Nj Prop.-Liab. Ins. Guaranty Ass'n green
njsuperctappdiv · 1980
2 sentences

1990Eastern Seaboard, 175 N.J.Super. at 592 , 421 A.2d at 599 ; accord 17 Fletcher, Encyclopedia of Private Corporations § 8300, at 10 (1977); 36 Am.Jur.2d Foreign Corporations § 37, at 52 (1968).

1990Eastern Seaboard, 175 N.J.Super. at 592 , 421 A.2d at 599 ; accord 17 Fletcher, Encyclopedia of Private Corporations § 8300, at 10 (1977); 36 Am.Jur.2d Foreign Corporations § 37, at 52 (1968).

11990–1990
Supreme Court of NH v. Piper green
scotus · 1985
1 sentence

1987In Piper , the Court held that a residency requirement was improper because the class of all nonresidents was not a peculiar source of the evils of low ethical behavior and unfamiliarity with local practice at which the rule was aimed. 2 Id.

11987–1987

Where else courts name it

NY 87 (1974–2025) IL 43 (1977–2026) PA 42 (1968–2026) MI 39 (1968–2025) TX 39 (1975–2024) CA 37 (1970–2026) OH 35 (1975–2025) FL 31 (1966–2025) NJ 27 (1970–2021) AL 19 (1974–2026) CT 17 (1979–2024) AR 15 (1981–2024) WA 14 (1974–2025) MN 14 (1971–2016) MA 13 (1971–2020) MS 13 (1976–2023) WI 12 (1976–2016) AK 12 (1973–2024) IA 12 (1982–2024) MO 10 (1976–2020) GA 10 (1978–2025) WV 10 (1979–2019) RI 9 (1990–2023) MD 9 (1967–2021) KY 8 (2002–2025) IN 8 (1986–2019) LA 7 (1975–2025) AZ 6 (1972–2024) CO 6 (1983–2025) TN 6 (1991–2019) VT 6 (1971–2016) OK 6 (1977–2015) NC 5 (1984–2025) NV 5 (1978–2022) ID 4 (1972–2005) NE 4 (1982–2021) ME 4 (1980–2020) HI 4 (1972–2012) KS 3 (1978–1992) VI 3 (1987–2017) DE 3 (2001–2021) SD 3 (1978–2005) NH 2 (1993–2014) WY 2 (1994–1997) VA 2 (1972–2023) NM 2 (1990–2015) ND 2 (1974–2020) UT 2 (2016–2021) DC 2 (1993–2024) OR 2 (2001–2022)

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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