substantial-compliance standard (Iowa) · Go Syfert
← Iowa issues

substantial-compliance standard in Iowa

12 Iowa opinions name it 2 courts 2002–2025 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
State v. Myersgreen
iowa · 2002 · cited in 5 Iowa opinions naming this issue, 2016–2018
2 sentences

2018See State v. Myers , 653 N.W.2d 574 , 578 (Iowa 2002) ("Under the substantial-compliance standard, a trial court is not required to advise a defendant of his rights using the precise language of the rule; it is sufficient that the defendant be informed of his rights in such a way that he is made aware of them."); see, e.g. , State v. Aherns , No. 13-1026, 2016 WL 351235 , at *3 (Iowa Ct. App. Jan. 27, 2016) (holding that telling a defendant he "could cross-examine the State's witness" met the substantial compliance standard concerning rights to cross-examine and confrontation); State v. Taylor

2017“Under the substantial-compliance standard, a trial court is not required to advise a defendant of his rights using the precise language of the rule; it is sufficient that the defendant be informed of his rights in such a way that he is made aware of them.” State v. Myers, 653 N.W.2d 574, 578 (Iowa 2002).

55
State of Iowa v. Kevin Duane Fisher IIgreen
iowa · 2016 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017More recently, the supreme court reiterated the substantial-compliance standard in a case involving the factual basis for a guilty plea by saying “insubstantial errors should not entitle a defendant to relief.” Finney, 834 N.W.2d at 62 ; see also State v. Fisher, 877 N.W.2d 676, 682 (using “a substantial compliance standard to determine whether a plea crosses the rule 2.8(2)(b)(2) threshold”5 ).

2017More recently, the supreme court reiterated the substantial-compliance standard in a case involving the factual basis for a guilty plea by saying “insubstantial errors should not entitle a defendant to relief.” Finney, 834 N.W.2d at 62 ; see also State v. Fisher, 877 N.W.2d 676, 682 (using “a substantial compliance standard to determine whether a plea crosses the rule 2.8(2)(b)(2) threshold”5 ).

22
State v. Loyegreen
iowa · 2003 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See State v. Loye, 670 N.W.2d 141, 150 (Iowa 2003); see also State v. Barnes, 652 N.W.2d 466, 467 (Iowa 2002) (finding that signing a written guilty plea that clearly states the substance of the rule requirements is sufficient to properly inform the defendant).

11
State v. Barnesgreen
iowa · 2002 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See State v. Loye, 670 N.W.2d 141, 150 (Iowa 2003); see also State v. Barnes, 652 N.W.2d 466, 467 (Iowa 2002) (finding that signing a written guilty plea that clearly states the substance of the rule requirements is sufficient to properly inform the defendant).

11
Brown v. John Deere Waterloo Tractor Worksgreen
iowa · 1988 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019See generally *654 Brown v. John Deere Waterloo Tractor Works , 423 N.W.2d 193 , 194 (Iowa 1988) ("[W]e have consistently held that substantial-not literal-compliance with section 17A.19(2) is all that is necessary to invoke the jurisdiction of the district court.").

11
State v. Westgreen
iowa · 1982 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017See State v. Kress, 636 N.W.2d 12, 21-22 (Iowa 2001) (noting the guilty-plea court misinformed the defendant that it could waive the one-third mandatory minimum sentence which “was tantamount to a failure to advise her of the maximum possible punishment”); State v. White, 587 N.W.2d 240, 246 (Iowa 1998) (concluding the failure to inform a defendant of the possibility of consecutive sentences leaves the defendant “partially informed, but uninformed of the true maximum possible punishment” and results in the plea being “uninformed and unenlightened”); but see Stovall v. State, 340 N.W.2d 265, 26

11
State v. Whitegreen
iowa · 1998 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017See State v. Kress, 636 N.W.2d 12, 21-22 (Iowa 2001) (noting the guilty-plea court misinformed the defendant that it could waive the one-third mandatory minimum sentence which “was tantamount to a failure to advise her of the maximum possible punishment”); State v. White, 587 N.W.2d 240, 246 (Iowa 1998) (concluding the failure to inform a defendant of the possibility of consecutive sentences leaves the defendant “partially informed, but uninformed of the true maximum possible punishment” and results in the plea being “uninformed and unenlightened”); but see Stovall v. State, 340 N.W.2d 265, 26

11
State v. Kressgreen
iowa · 2001 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017See State v. Kress, 636 N.W.2d 12, 21-22 (Iowa 2001) (noting the guilty-plea court misinformed the defendant that it could waive the one-third mandatory minimum sentence which “was tantamount to a failure to advise her of the maximum possible punishment”); State v. White, 587 N.W.2d 240, 246 (Iowa 1998) (concluding the failure to inform a defendant of the possibility of consecutive sentences leaves the defendant “partially informed, but uninformed of the true maximum possible punishment” and results in the plea being “uninformed and unenlightened”); but see Stovall v. State, 340 N.W.2d 265, 26

11
State v. Strawgreen
iowa · 2006 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016See Straw, 709 N.W.2d at 132 .

11
State v. Smothersgreen
iowa · 1981 · cited in 1 Iowa opinions naming this issue, 2002–2002
1 sentence

2002See State v. Smothers, 309 N.W.2d 506, 508 (Iowa 1981).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Stovall v. Stategreen
iowa · 1983 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017See State v. Kress, 636 N.W.2d 12, 21-22 (Iowa 2001) (noting the guilty-plea court misinformed the defendant that it could waive the one-third mandatory minimum sentence which “was tantamount to a failure to advise her of the maximum possible punishment”); State v. White, 587 N.W.2d 240, 246 (Iowa 1998) (concluding the failure to inform a defendant of the possibility of consecutive sentences leaves the defendant “partially informed, but uninformed of the true maximum possible punishment” and results in the plea being “uninformed and unenlightened”); but see Stovall v. State, 340 N.W.2d 265, 26

11

Also cited on this issue (3)

CaseCitedYears
State of Iowa v. Craig Anthony Finney green
iowa · 2013
2 sentences

2017More recently, the supreme court reiterated the substantial-compliance standard in a case involving the factual basis for a guilty plea by saying “insubstantial errors should not entitle a defendant to relief.” Finney, 834 N.W.2d at 62 ; see also State v. Fisher, 877 N.W.2d 676, 682 (using “a substantial compliance standard to determine whether a plea crosses the rule 2.8(2)(b)(2) threshold”5 ).

2017More recently, the supreme court reiterated the substantial-compliance standard in a case involving the factual basis for a guilty plea by saying “insubstantial errors should not entitle a defendant to relief.” Finney, 834 N.W.2d at 62 ; see also State v. Fisher, 877 N.W.2d 676, 682 (using “a substantial compliance standard to determine whether a plea crosses the rule 2.8(2)(b)(2) threshold”5 ).

22017–2017
State v. Carter green
iowa · 2000
1 sentence

2025In State v. Carter, we analyzed whether a certification that did not include the “subject to penalty of perjury” language nonetheless subjected a defendant to a perjury charge based on substantial compliance with § 622.1(1). 618 N.W.2d at 375 .

12025–2025
Isaac Ortiz v. Loyd Roling Construction and Grinnell Mutual Reinsurance green
iowa · 2019
2 sentences

2020We “acknowledge[d] that the leeway permitted under the substantial-compliance doctrine would not normally include using a 8 means of communication different than provided under the statute.” 928 N.W.2d at 654 .

2020Yet we added that “we have in the past construed statutes written in an era that fit the means of communication at the time but were later displaced by different forms of communication.” Id. at 655 .

12020–2020

Statutes the citing opinions construe

IA § Iowa Code § 911.1 (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

OH 157 (1992–2026) AR 14 (1998–2025) IA 12 (2002–2025) TX 11 (2008–2024) MI 5 (2012–2025) MN 5 (2001–2016) AL 3 (1999–2000) MS 3 (2007–2012) NV 3 (2010–2021) NJ 3 (2021–2026) CO 2 (2018–2021) WI 2 (1987–1996) AZ 2 (2006–2017) CA 2 (2000–2004)

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.

← Caselaw search · G Cite Topics · Brief Check