State relies doctrine (Iowa) · Go Syfert
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State relies doctrine in Iowa

10 Iowa opinions name it 2 courts 1976–2024 1 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 (10)

CaseFollowedCited
State of Iowa v. Jesse Michael Gaskinsgreen
iowa · 2015 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024That exception “derives from interests in officer safety and evidence preservation that are typically implicated in arrest situations.” Gant, 556 U.S. at 338 ; accord Gaskins, 866 N.W.2d at 8 .

11
State v. Cerongreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019“A lawful arrest is, of course, a predicate for a lawful search incident to the arrest.” State v. Ceron, 573 N.W.2d 587, 589 (Iowa 1997).

11
Vonda Kay Wilson v. Commonwealth of Virginiagreen
vactapp · 1999 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017The State relies on the analysis from a similar sentencing challenge before a Virginia appellate court, quoting: “Nowhere in the ADA does it appear that Congress intended the Act to provide rights that could be asserted in a criminal proceeding . . . .” See Wilson v. Commonwealth, 522 S.E.2d 385, 387 (Va. Ct. App. 1999).

11
State v. Kirchoffgreen
iowa · 1990 · cited in 1 Iowa opinions naming this issue, 2002–2002
1 sentence

2002(Emphasis added.) We held in State v. Kirchoff, 452 N.W.2d 801, 804 (Iowa 1990), that substantial compliance with this rule is all that is required, and the State relies on that principle here.

11
New York v. Beltonred
scotus · 1981 · cited in 1 Iowa opinions naming this issue, 1998–1998
2 sentences

1998In an attempt to draw a bright-line rule in cases involving vehicle searches incident to arrest, the Supreme Court held in New York v. Belton that when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile. 453 U.S. 454, 460 , 101 S.Ct. 2860, 2864 , 69 L.Ed.2d 768, 775 (1981) (footnotes omitted).

1998In an attempt to draw a bright-line rule in cases involving vehicle searches incident to arrest, the Supreme Court held in New York v. Belton that when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile. 453 U.S. 454, 460 , 101 S.Ct. 2860, 2864 , 69 L.Ed.2d 768, 775 (1981) (footnotes omitted).

11
State v. Hartunggreen
iowa · 1948 · cited in 1 Iowa opinions naming this issue, 1976–1976
2 sentences

1976See Rule 196, Rules of Civil Procedure; State v. Smith, 215 N.W.2d 225, 227 (Iowa 1974); State v. Dague, 206 N.W.2d 93, 95 (Iowa 1973); State v. Cox, 196 N.W.2d 430, 432 (Iowa 1972); State v. Hartung, 239 Iowa 414, 423-424 , 30 N.W.2d 491, 497 (1948).

1976See Rule 196, Rules of Civil Procedure; State v. Smith, 215 N.W.2d 225, 227 (Iowa 1974); State v. Dague, 206 N.W.2d 93, 95 (Iowa 1973); State v. Cox, 196 N.W.2d 430, 432 (Iowa 1972); State v. Hartung, 239 Iowa 414, 423-424 , 30 N.W.2d 491, 497 (1948).

11
State v. Coxgreen
iowa · 1972 · cited in 1 Iowa opinions naming this issue, 1976–1976
1 sentence

1976See Rule 196, Rules of Civil Procedure; State v. Smith, 215 N.W.2d 225, 227 (Iowa 1974); State v. Dague, 206 N.W.2d 93, 95 (Iowa 1973); State v. Cox, 196 N.W.2d 430, 432 (Iowa 1972); State v. Hartung, 239 Iowa 414, 423-424 , 30 N.W.2d 491, 497 (1948).

11
State v. Smithgreen
iowa · 1974 · cited in 1 Iowa opinions naming this issue, 1976–1976
1 sentence

1976See Rule 196, Rules of Civil Procedure; State v. Smith, 215 N.W.2d 225, 227 (Iowa 1974); State v. Dague, 206 N.W.2d 93, 95 (Iowa 1973); State v. Cox, 196 N.W.2d 430, 432 (Iowa 1972); State v. Hartung, 239 Iowa 414, 423-424 , 30 N.W.2d 491, 497 (1948).

11
State v. Daguegreen
iowa · 1973 · cited in 1 Iowa opinions naming this issue, 1976–1976
1 sentence

1976See Rule 196, Rules of Civil Procedure; State v. Smith, 215 N.W.2d 225, 227 (Iowa 1974); State v. Dague, 206 N.W.2d 93, 95 (Iowa 1973); State v. Cox, 196 N.W.2d 430, 432 (Iowa 1972); State v. Hartung, 239 Iowa 414, 423-424 , 30 N.W.2d 491, 497 (1948).

11
State v. Clarkgreen
iowa · 1971 · cited in 1 Iowa opinions naming this issue, 1976–1976
2 sentences

1976The State relies on rule 196, Rules of Civil Procedure, and State v. Clark, 187 N.W.2d 717, 719 (Iowa 1971) and State v. Schmidt, 259 Iowa 972, 979-980 , 145 N.W.2d 631, 636 , as support for its position.

1976The State relies on rule 196, Rules of Civil Procedure, and State v. Clark, 187 N.W.2d 717, 719 (Iowa 1971) and State v. Schmidt, 259 Iowa 972, 979-980 , 145 N.W.2d 631, 636 , as support for its position.

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 (4)

CaseCitedYears
Illinois v. Rodriguez green
scotus · 1990
2 sentences

2016The doctrine has its genesis in the United States Supreme Court’s decision in Illinois v. Rodriguez, 497 U.S. 177 , 110 S. Ct. 2793 , 111 L.

2016The doctrine has its genesis in the United States Supreme Court’s decision in Illinois v. Rodriguez, 497 U.S. 177 , 110 S. Ct. 2793 , 111 L.

32016–2016
Arizona v. Gant green
scotus · 2009
1 sentence

2024That exception “derives from interests in officer safety and evidence preservation that are typically implicated in arrest situations.” Gant, 556 U.S. at 338 ; accord Gaskins, 866 N.W.2d at 8 .

12024–2024
State v. Howard green
iowa · 1993
1 sentence

1998One exception is a search incident to arrest, id. at 766-67 , and the State relies on that exception here.

11998–1998
State v. Schmidt green
iowa · 1966
2 sentences

1976The State relies on rule 196, Rules of Civil Procedure, and State v. Clark, 187 N.W.2d 717, 719 (Iowa 1971) and State v. Schmidt, 259 Iowa 972, 979-980 , 145 N.W.2d 631, 636 , as support for its position.

1976The State relies on rule 196, Rules of Civil Procedure, and State v. Clark, 187 N.W.2d 717, 719 (Iowa 1971) and State v. Schmidt, 259 Iowa 972, 979-980 , 145 N.W.2d 631, 636 , as support for its position.

11976–1976

Statutes the citing opinions construe

IA § Iowa Code § 711.3 (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

OR 10 (1998–2024) IA 10 (1976–2024) TX 9 (1971–2019) IL 8 (1955–2023) WA 8 (1984–2025) NM 7 (1990–2025) IN 6 (1999–2014) CT 5 (1986–2023) KS 4 (1921–2022) GA 4 (2001–2012) MO 4 (1971–2017) AL 3 (1955–1985) NC 3 (1977–2009) FL 3 (1974–2018) MD 2 (1995–2012) AZ 2 (1973–1977)

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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