defendant waived error (Iowa) · Go Syfert
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defendant waived error in Iowa

11 Iowa opinions name it 2 courts 1879–2022 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 (6)

CaseFollowedCited
In Re: The PEOPLE of the State of Colorado v. Juan Johnny HERNANDEZgreen
colo · 2021 · cited in 2 Iowa opinions naming this issue, 2022–2022
2 sentences

2022App. Feb. 2, 2022) (refusing to apply even plain-error review to defendant’s unpreserved claim of public trial violation); Poe, 2021 WL 5578080 , at *2 (“Poe’s ‘failure to object’ forfeited ‘his right [to have his family present at sentencing] . . . preclud[ing] any subsequent challenge by him of an order excluding the public.’ ” (alterations and omission in original) (quoting People v. Virgil, 253 P.3d 553, 578 (Cal. 2011))); People v. Hernandez, 488 P.3d 1055, 1063 (Colo. 2021) (en banc) (holding that the defendant waived his claim of error by failing to “raise th[e] argument below,” without

2022App. Feb. 2, 2022) (refusing to apply even plain-error review to defendant’s unpreserved claim of public trial violation); Poe, 2021 WL 5578080 , at *2 (“Poe’s ‘failure to object’ forfeited ‘his right [to have his family present at sentencing] . . . preclud[ing] any subsequent challenge by him of an order excluding the public.’ ” (alterations and omission in original) (quoting People v. Virgil, 253 P.3d 553, 578 (Cal. 2011))); People v. Hernandez, 488 P.3d 1055, 1063 (Colo. 2021) (en banc) (holding that the defendant waived his claim of error by failing to “raise th[e] argument below,” without

22
People v. Virgilgreen
cal · 2011 · cited in 2 Iowa opinions naming this issue, 2022–2022
2 sentences

2022App. Feb. 2, 2022) (refusing to apply even plain-error review to defendant’s unpreserved claim of public trial violation); Poe, 2021 WL 5578080 , at *2 (“Poe’s ‘failure to object’ forfeited ‘his right [to have his family present at sentencing] . . . preclud[ing] any subsequent challenge by him of an order excluding the public.’ ” (alterations and omission in original) (quoting People v. Virgil, 253 P.3d 553, 578 (Cal. 2011))); People v. Hernandez, 488 P.3d 1055, 1063 (Colo. 2021) (en banc) (holding that the defendant waived his claim of error by failing to “raise th[e] argument below,” without

2022App. Feb. 2, 2022) (refusing to apply even plain-error review to defendant’s unpreserved claim of public trial violation); Poe, 2021 WL 5578080 , at *2 (“Poe’s ‘failure to object’ forfeited ‘his right [to have his family present at sentencing] . . . preclud[ing] any subsequent challenge by him of an order excluding the public.’ ” (alterations and omission in original) (quoting People v. Virgil, 253 P.3d 553, 578 (Cal. 2011))); People v. Hernandez, 488 P.3d 1055, 1063 (Colo. 2021) (en banc) (holding that the defendant waived his claim of error by failing to “raise th[e] argument below,” without

22
State v. Mudragreen
iowa · 1995 · cited in 2 Iowa opinions naming this issue, 2014–2014
2 sentences

2014See id.

2014See id.

22
State v. Escobedogreen
iowactapp · 1997 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022See State v. Sage, 162 N.W.2d 502, 504 (Iowa 1968) (stating that, generally, a criminal defendant cannot take a position on appeal inconsistent with a position taken at trial or complain of error to which the defendant consented or invited); see also State v. Escobedo, 573 N.W.2d 271, 276 (Iowa Ct. App. 1997) (noting that although a defendant would ordinarily be entitled to a mistrial based on dismissal of a juror during deliberations, the defendant waived error by agreeing to juror’s replacement with an alternate).

11
State v. Dudleygreen
iowa · 2009 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022See State v. Dudley, 766 N.W.2d 606, 612 (Iowa 2009).1 1In State v. McCalley, we concluded the defendant waived her challenge to application of Iowa Code section 910.2A to her sentence by “failing to avail herself of multiple opportunities to timely request a determination on her ability to pay.” 972 N.W.2d 672 , 680 (Iowa 2022).

11
State v. Sagegreen
iowa · 1968 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022See State v. Sage, 162 N.W.2d 502, 504 (Iowa 1968) (stating that, generally, a criminal defendant cannot take a position on appeal inconsistent with a position taken at trial or complain of error to which the defendant consented or invited); see also State v. Escobedo, 573 N.W.2d 271, 276 (Iowa Ct. App. 1997) (noting that although a defendant would ordinarily be entitled to a mistrial based on dismissal of a juror during deliberations, the defendant waived error by agreeing to juror’s replacement with an alternate).

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 (5)

CaseCitedYears
State v. Jones green
iowa · 1978
1 sentence

2011Id.

12011–2011
Herman v. Brewer green
iowa · 1972
1 sentence

1998Herman, 193 N.W.2d at 545 .

11998–1998
Dorman v. Credit Reference & Reporting Co. green
iowa · 1932
1 sentence

1932Dorman v. Credit Reference Company, supra. *1355 II. 'Appellant attacks Instruction No. 3, reading as follows: “The particular acts of negligence complained of by the plaintiff and submitted to you herewith are as follows: “1.

11932–1932
Eckles v. Kinney neutral
iowa · 1857
1 sentence

1912In one of these cases it is said: “Although the defendant, after the order for the change of venue had been made, might well object to any order being made at a subsequent term to redocket the cause, yet, as it appears that he made no objection in the case, and appeared in court by his attorneys and went to trial, he can not now assign the ruling of the district court for error.” Eckles v. Kinney, 4 Iowa, 539 .

11912–1912
Coakley v. McCarty neutral
iowa · 1871
1 sentence

1879Coakley v. McCarty, 34 Iowa, 105 , and cases cited. .2. dvidiekce : railroads: personai injuries, II.

11879–1879

Statutes the citing opinions construe

IA § Iowa Code § 709.4 (3) IA § Iowa Code § 814.28 (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

NY 88 (1917–2025) CT 62 (1971–2026) TX 30 (1961–2024) PA 26 (1980–2026) IL 24 (1908–2023) CA 16 (1896–2026) MA 16 (1919–2026) FL 15 (1959–2018) MO 14 (1906–2019) IN 13 (1995–2025) WA 12 (1906–2024) IA 11 (1879–2022) TN 9 (2004–2026) LA 7 (1913–2021) AZ 7 (1965–2024) MI 7 (1983–2026) OK 6 (1927–2005) NC 6 (1876–2024) GA 5 (1998–2021) NE 5 (1990–2013) WI 4 (1989–2022) CO 4 (1927–2025) MN 3 (1980–2014) RI 3 (1981–1986) OH 3 (2006–2025) ME 2 (2016–2016) WV 2 (1945–1980) NM 2 (2004–2020) SD 2 (1985–2022) AL 2 (1972–1973) NJ 2 (1989–2002) MD 2 (2014–2015) VT 2 (1894–1940) MT 2 (1987–2008)

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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