fails rule in Iowa

2022See Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citation omitted)); State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (“[W]hen a court fails to rule on a matter, a party must request a ruling by some means.”).

2019See State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (“[W]hen a court fails to rule on a matter, a party must request a ruling by some means.”).

2022See Lamasters, 821 N.W.2d at 863 (requiring a party to file a rule 1.904 motion requesting a ruling to preserve error when the court fails to rule on the issue in its initial order). 8 Even if the argument were preserved, Harris neglected to establish any specific error that occurred during the jury selection or opening statements or how he was prejudiced; therefore, his challenge must fail.

2022See Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” (citation omitted)); State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (“[W]hen a court fails to rule on a matter, a party must request a ruling by some means.”).

2022Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (holding that in order to preserve error on appeal where the trial court fails to rule, a motion requesting a ruling is required to preserve error).

2015See Lamasters v. State, 821 N.W.2d 856 , 863–64 (Iowa 2012) (noting rule 1.904(2) “is one means, but not the only means, for requesting” a ruling on a matter in order to preserve error); State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (stating that “when a court fails to rule on a matter, a party must request a ruling by some means”); see also Meier v. Senecaut, 641 N.W.2d 532, 539 (Iowa 2002).

2022See State v. Oetken, 613 N.W.2d 679, 689 (Iowa 2000) (finding counsel was not ineffective when the defendant did not “assert any specific error occurred during the course of those proceedings, or that he was prejudiced as a result of his trial counsel’s representation”). 9 Harris also claims his counsel was ineffective for not objecting when the State “improperly shifted the burden [of proof]” to Harris during closing statements.

2012See, e.g., State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (stating that “when a court fails to rule on a matter, a party must request a ruling by some means”); Fennelly v. A-1 Mach. & Tool Co., 728 N.W.2d 181, 187 (Iowa 2007) (finding a claim that was not addressed in the district court’s summary judgment order and not subsequently brought to the court’s attention had not been preserved for appeal); Stammeyer v. Div. of Narcotics Enforcement, 721 N.W.2d 541, 548 (Iowa 2006) (finding an argument not preserved for appeal when there was “nothing indicating 1However, we have cautioned that a r

2012See, e.g., State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (stating that “when a court fails to rule on a matter, a party must request a ruling by some means”); Fennelly v. A-1 Mach. & Tool Co., 728 N.W.2d 181, 187 (Iowa 2007) (finding a claim that was not addressed in the district court’s summary judgment order and not subsequently brought to the court’s attention had not been preserved for appeal); Stammeyer v. Div. of Narcotics Enforcement, 721 N.W.2d 541, 548 (Iowa 2006) (finding an argument not preserved for appeal when there was “nothing indicating the court ruled upon or even conside

2012See In re Marriage of Okland, 699 N.W.2d 260 , 265–66 & n.2 (Iowa 2005). 11 the court ruled upon or even considered [it]”); Boyle v. Alum-Line, Inc., 710 N.W.2d 741 , 751 n.4 (Iowa 2006) (stating that “[w]hen a district court fails to rule on an issue properly raised by a party, the party who raised the issue must file a motion requesting a ruling in order to preserve error for appeal”).

2012See, e.g., State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (stating that “when a court fails to rule on a matter, a party must request a ruling by some means”); Fennelly v. A-1 Mach. & Tool Co., 728 N.W.2d 181, 187 (Iowa 2007) (finding a claim that was not addressed in the district court’s summary judgment order and not subsequently brought to the court’s attention had not been preserved for appeal); Stammeyer v. Div. of Narcotics Enforcement, 721 N.W.2d 541, 548 (Iowa 2006) (finding an argument not preserved for appeal when there was “nothing indicating 1However, we have cautioned that a r

2012See, e.g., State v. Krogmann, 804 N.W.2d 518, 524 (Iowa 2011) (stating that “when a court fails to rule on a matter, a party must request a ruling by some means”); Fennelly v. A-1 Mach. & Tool Co., 728 N.W.2d 181, 187 (Iowa 2007) (finding a claim that was not addressed in the district court’s summary judgment order and not subsequently brought to the court’s attention had not been preserved for appeal); Stammeyer v. Div. of Narcotics Enforcement, 721 N.W.2d 541, 548 (Iowa 2006) (finding an argument not preserved for appeal when there was “nothing indicating the court ruled upon or even conside