Harrington claim in Iowa

2025See Smith, 924 N.W.2d at 851 (“[N]o offender in a habitual offender stipulation proceeding should suffer Harrington’s error preservation sanction unless the court has complied with its duty under Harrington to inform the offender that challenges to the stipulation proceedings must be raised in a motion in arrest of judgment and the failure to do so precludes raising those challenges on appeal.”). 10 offender.

2020The amendment does not apply to Purtilo, whose conviction and sentence became final before the effective date. 3 Purtilo agrees he “did not file a motion in arrest of judgment,” but he argues “[t]here is nothing in the guilty plea form” that indicated his plea to “2 prior” convictions “was tied to the right to challenge that so-called stipulation through a motion.” See Smith, 924 N.W.2d at 851 (“[N]o offender in a habitual offender stipulation proceeding should suffer Harrington’s error preservation sanction unless the court has complied with its duty under Harrington to inform the offender th

2022“The prosecution ‘has a duty to learn of any favorable evidence known to . . . others acting on the government’s behalf in the case, including the police.’” DeSimone, 803 N.W.2d at 103 (alteration in original) (citation omitted).

2021As authority, Harrington relies on Allison v. State. 914 N.W.2d 866, 891 (Iowa 2018).5 There our supreme court held: that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging postconviction counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for 5 Harrington’s brief argues that Allison should apply retroactively.

2020The amendment does not apply to Purtilo, whose conviction and sentence became final before the effective date. 3 Purtilo agrees he “did not file a motion in arrest of judgment,” but he argues “[t]here is nothing in the guilty plea form” that indicated his plea to “2 prior” convictions “was tied to the right to challenge that so-called stipulation through a motion.” See Smith, 924 N.W.2d at 851 (“[N]o offender in a habitual offender stipulation proceeding should suffer Harrington’s error preservation sanction unless the court has complied with its duty under Harrington to inform the offender th

2019See, e.g. , State v. Meron , 675 N.W.2d 537 , 541 (Iowa 2004) (noting court's failure to inform the defendant entering guilty plea of those two pieces of information as required by rule 2.8(2)( d ) excuses the defendant's failure to challenge the guilty plea proceedings by filing a motion in arrest of judgment).

2019See, e.g. , State v. Meron , 675 N.W.2d 537 , 541 (Iowa 2004) (noting court's failure to inform the defendant entering guilty plea of those two pieces of information as required by rule 2.8(2)( d ) excuses the defendant's failure to challenge the guilty plea proceedings by filing a motion in arrest of judgment).

2018See State v. Steiger, 903 N.W.2d 169, 170 (Iowa 2017) (reversing for failure to comply with colloquy despite no motion in arrest of judgment because Harrington’s error-preservation rule was not established at time of colloquy).

2016See 579 N.W.2d at 822 .

2016See 579 N.W.2d at 822 .

2003See Brady v. Maryland, 373 U.S. 83, 87 , 83 S.Ct. 1194, 1196-97 , 10 L.Ed.2d 215, 218 (1963) (holding failure of prosecution to disclose evidence that may be favorable to the accused is a violation of the Due Process Clause of the Fourteenth Amendment).

2003See Brady v. Maryland, 373 U.S. 83, 87 , 83 S.Ct. 1194, 1196-97 , 10 L.Ed.2d 215, 218 (1963) (holding failure of prosecution to disclose evidence that may be favorable to the accused is a violation of the Due Process Clause of the Fourteenth Amendment).

2003Harrington v. Nix, 983 F.2d 872, 875 (8th Cir.1993). .

2003Harrington v. Nix, 983 F.2d 872, 875 (8th Cir.1993). [4] The murder weapon itself was never found.

2003In order to establish a Brady violation, the defendant had to prove “(1) the prosecution suppressed evidence; (2) the evidence was favorable to the defendant; and (3) the evidence was material to the issue of guilt.” State v. Veal, 564 N.W.2d 797, 810 (Iowa 1997), overruled in part on other grounds by State v. Hallum, 585 N.W.2d 249, 253 (Iowa 1998).

2003In order to establish a Brady violation, the defendant had to prove "(1) the prosecution suppressed evidence; (2) the evidence was favorable to the defendant; and (3) the evidence was material to the issue of guilt." State v. Veal, 564 N.W.2d 797, 810 (Iowa 1997), overruled in part on other grounds by State v. Hallum, 585 N.W.2d 249, 253 (Iowa 1998).

2003In order to establish a Brady violation, the defendant had to prove “(1) the prosecution suppressed evidence; (2) the evidence was favorable to the defendant; and (3) the evidence was material to the issue of guilt.” State v. Veal, 564 N.W.2d 797, 810 (Iowa 1997), overruled in part on other grounds by State v. Hallum, 585 N.W.2d 249, 253 (Iowa 1998).

2003In order to establish a Brady violation, the defendant had to prove "(1) the prosecution suppressed evidence; (2) the evidence was favorable to the defendant; and (3) the evidence was material to the issue of guilt." State v. Veal, 564 N.W.2d 797, 810 (Iowa 1997), overruled in part on other grounds by State v. Hallum, 585 N.W.2d 249, 253 (Iowa 1998).

1989The Iowa Supreme Court recently adopted the federal standard for summary judgment as set out in Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 244 , 106 S.Ct. 2505, 2508 , 91 L.Ed.2d 202, 209 (1986).

1989The Iowa Supreme Court recently adopted the federal standard for summary judgment as set out in Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 244 , 106 S.Ct. 2505, 2508 , 91 L.Ed.2d 202, 209 (1986).