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10 Iowa opinions name it 2 courts 2014–2026 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.
| Case | Followed | Cited |
|---|---|---|
Matter of Mohrgreen2 sentences2026“Behavior that is socially unacceptable, standing alone, does not satisfy the overt act requirement.” L.E.B., 2015 WL 7575399 , at *3 (citing In re Mohr, 383 N.W.2d 539, 542 (Iowa 1986)). 2025“Behavior that is socially unacceptable, standing alone, does not satisfy the overt act requirement.” L.E.B., 2015 WL 7575399 , at *3 (citing In re Mohr, 383 N.W.2d 539, 542 (Iowa 1986)). | 5 | 6 |
Matter of Fostergreen2 sentences2026Instead, the “‘overt act’ must indicate ‘past aggressive behavior or threats’ that manifest ‘the probable commission of a dangerous act’ by the respondent ‘that is likely to result in physical injury.’” V.H., 996 N.W.2d at 544 (quoting In re Foster, 426 N.W.2d 374, 378 (Iowa 1988)). 2020The respondent’s strange statements played some role in the altercations, however the Iowa Supreme Court held the overt-act requirement unsatisfied, saying, “[p]rovoking acts of aggression toward oneself by bizarre or socially unacceptable behavior does not elevate such behavior to a level of likely physical injury to oneself.” Id. at 379 . | 2 | 3 |
Matter of Personal Restraint of Youngred2 sentences2018The Washington Supreme Court held in In re Personal Restraint of Young that the recent overt-act requirement is generally mandated by due process because the state must show current dangerousness. 122 Wash.2d 1 , 857 P.2d 989 , 1008 (1993) (en banc), superseded by statute on other grounds , Wash. Rev. 2018The Washington Supreme Court held in In re Personal Restraint of Young that the recent overt-act requirement is generally mandated by due process because the state must show current dangerousness. 122 Wash.2d 1 , 857 P.2d 989 , 1008 (1993) (en banc), superseded by statute on other grounds , Wash. Rev. | 2 | 2 |
In Re Albrechtgreen2 sentences2018Albrecht, 51 P.3d at 78 (holding the state was required to show proof of a recent overt act for individual who was recently released from incarceration into the community). 2018Albrecht , 51 P.3d at 78 (holding the state was required to show proof of a recent overt act for individual who was recently released from incarceration into the community). | 2 | 2 |
In Re Detention of Gonzalesgreen1 sentence2018See In re Det. of Gonzales, 658 N.W.2d 102, 104 (Iowa 2003). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Detention of Thorell
green
2 sentences2018Code Ann. §§ 71.09.020 , .090–.098 (West), as recognized in In re Det. of Thorell, 72 P.3d 708 , 720–21 (2003) (en banc). 2018Code Ann. §§ 71.09.020 , .090-.098 (West), as recognized in In re Det. of Thorell , 149 Wash.2d 724 , 72 P.3d 708 , 720-21 (2003) (en banc). | 2 | 2018–2018 |
In re the Detention of Thorell
green
1 sentence2018Code Ann. §§ 71.09.020 , .090-.098 (West), as recognized in In re Det. of Thorell , 149 Wash.2d 724 , 72 P.3d 708 , 720-21 (2003) (en banc). | 1 | 2018–2018 |
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.
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.