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

11 Iowa opinions name it 2 courts 1880–2023 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 (6)

CaseFollowedCited
State v. Johnsongreen
iowa · 2008 · cited in 4 Iowa opinions naming this issue, 2015–2023
2 sentences

2023She claims that adding the phrase “remaining payable to [Wesley] after any prior division” altered her share of the pension so that it no longer reflects the intent of the court in entering the dissolution decree. “[N]unc pro tunc orders are limited to situations where there is an obvious error that needs correction or where it is necessary to conform the order to the court’s original intent.” State v. Johnson, 744 N.W.2d 646, 648 (Iowa 2008).

2022See State v. Johnson, 744 N.W.2d 646, 649 (Iowa 2008) (“[N]unc pro tunc orders are limited to situations where there is an obvious error that needs correction or where it is necessary to conform the order to the court’s original intent.”). 2 This provision has since been renumbered as Iowa Code section 709.4(1)(b)(2)(a).

44
Harrington v. Stategreen
iowa · 2003 · cited in 4 Iowa opinions naming this issue, 2018–2020
2 sentences

2020“In addition to the obvious requirement that an applicant relying on section 822.3 must show the alleged ground of fact could not have been raised earlier, the applicant must also show a nexus between the asserted ground of fact and the challenged conviction.” Harrington, 659 N.W.2d at 520 .

2020“In addition to the obvious requirement that an applicant relying on section 822.3 must show the alleged ground of fact could not have been raised earlier, the applicant 6 must also show a nexus between the asserted ground of fact and the challenged conviction.” Harrington v. State, 659 N.W.2d 509, 520 (Iowa 2003).

34
Dible v. Stategreen
iowa · 1996 · cited in 1 Iowa opinions naming this issue, 2003–2003
2 sentences

2003See Dible, 557 N.W.2d at 884 ; Hogan v. State, 454 N.W.2d 360, 361 (Iowa 1990).

2003See Dible, 557 N.W.2d at 884 ; Hogan v. State, 454 N.W.2d 360, 361 (Iowa 1990).

11
Hogan v. Stategreen
iowa · 1990 · cited in 1 Iowa opinions naming this issue, 2003–2003
2 sentences

2003See Dible, 557 N.W.2d at 884 ; Hogan v. State, 454 N.W.2d 360, 361 (Iowa 1990).

2003See Dible, 557 N.W.2d at 884 ; Hogan v. State, 454 N.W.2d 360, 361 (Iowa 1990).

11
Oswald v. LeGrandgreen
iowa · 1990 · cited in 1 Iowa opinions naming this issue, 1992–1992
2 sentences

1992See, e.g., Oswald v. LeGrand, 453 N.W.2d 634, 639-401 (Iowa 1990); Daiker v. Martin, 250 Iowa 75 , 91 N.W.2d 747, 752 (1958).

1992See, e.g., Oswald v. LeGrand, 453 N.W.2d 634, 639-401 (Iowa 1990); Daiker v. Martin, 250 Iowa 75 , 91 N.W.2d 747, 752 (1958).

11
Daiker v. Martingreen
iowa · 1958 · cited in 1 Iowa opinions naming this issue, 1992–1992
2 sentences

1992See, e.g., Oswald v. LeGrand, 453 N.W.2d 634, 639-401 (Iowa 1990); Daiker v. Martin, 250 Iowa 75 , 91 N.W.2d 747, 752 (1958).

1992See, e.g., Oswald v. LeGrand, 453 N.W.2d 634, 639-401 (Iowa 1990); Daiker v. Martin, 250 Iowa 75 , 91 N.W.2d 747, 752 (1958).

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 (1)

CaseCitedYears
Sullivan v. Frink & Co. neutral
· 1856
1 sentence

1880An award will be set aside for a mistake palpable upon its face; or for a plain mistake in the law upon some material point; or for a mistake in fact such as the arbitrator would himself admit, e. g. a miscalculation; or for a palpable mistake which is extremely prejudicial to the losing party; for a very gross and manifest mistake.” And on page 322 it is said: “ A report of referees may be set aside either for an evident mistake in a matter of fact, or for an obvious error in matters of law.” See also Sullivan v. Frink & Co., 3 Iowa, 66 .

11880–1880

Statutes the citing opinions construe

IA § Iowa Code § 822.3 (4) IA § Iowa Code § 822.2 (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 593 (1987–2026) ME 241 (1966–2026) ND 206 (1974–2026) CA 95 (1896–2026) MI 54 (1871–2026) UT 53 (1993–2026) TX 52 (1912–2025) WA 50 (1918–2026) GA 40 (1850–2024) PA 40 (1908–2025) IL 39 (1907–2025) NY 39 (1838–2024) CT 33 (1951–2025) MD 31 (1906–2026) AL 29 (1847–2026) MA 26 (1928–2025) MO 24 (1886–2022) OK 22 (1915–2024) FL 20 (1961–2014) CO 19 (1978–2026) NC 16 (1862–2021) NJ 15 (1884–2022) MS 14 (1844–2026) LA 14 (1871–2014) DC 14 (1957–2017) IN 12 (1842–2017) IA 11 (1880–2023) OR 11 (1904–2026) NM 11 (1914–2023) NE 11 (1902–2016) TN 9 (1829–2026) KY 9 (1959–2026) WY 7 (1983–2020) AR 7 (1910–2017) KS 7 (1891–2001) AK 7 (1982–2025) VT 6 (1988–2026) WI 5 (1971–2023) HI 5 (1951–2019) VA 5 (1884–2014) NH 4 (1847–1995) WV 4 (1947–1995) MN 4 (1964–2010) RI 4 (1902–2019) DE 3 (1972–2025) AZ 3 (1900–2006) NV 3 (1929–2000) MT 2 (1886–2015) SD 2 (1990–2003)

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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