first prong test in Iowa

1996State v. Hildebrant, 405 N.W.2d 839, 841 (Iowa 1987).

1995State v. Hildebrant, 405 N.W.2d 839, 841 (Iowa 1987).

2017See State v. Straw, 709 N.W.2d 128, 133 (Iowa 2006).

2017See State v. Straw, 709 N.W.2d 128, 133 (Iowa 2006) 5 To prove the first prong of this claim, Robinson must show counsel’s performance fell outside the normal range of competency.

2018The first prong of the test, established in Strickland v. Washington , 466 U.S. 668 , 687 (1984), requires a showing that counsel failed to perform an essential duty.

1986The first prong of the test requires a showing “that counsel made errors so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052, 2064 , 80 L.Ed.2d 674, 693 (1984).

2009Under the first prong of this test, counsel’s performance is measured “against the standard of a reasonably competent practitioner with the presumption that the attorney performed his duties in a competent *603 manner.” State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004).

2009The first prong of the test requires counsel's performance to be measured "`against the standard of a reasonably competent practitioner with the presumption that the attorney performed his duties in a competent manner.'" State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004) (quoting State v. Begey, 672 N.W.2d 747, 749 (Iowa 2003)). "[I]n order to satisfy the `prejudice' requirement, the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial." Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct.

2019Although not required to predict changes in the law, “counsel must ‘exercise reasonable diligence in deciding whether an issue is “worth raising.” ’ ” State v. Dudley, 766 N.W.2d 606, 620 (Iowa 2009) (quoting State v. Westeen, 591 N.W.2d 203, 210 (Iowa 1999)).

2019Although not required to predict changes in the law, "counsel must 'exercise reasonable diligence in deciding whether an issue is "worth raising." ' " State v. Dudley , 766 N.W.2d 606 , 620 (Iowa 2009) (quoting State v. Westeen , 591 N.W.2d 203 , 210 (Iowa 1999) ).

2017The first prong of the test is determined by comparing counsel’s work “against the standard of a reasonably competent practitioner, with the presumption that the attorney performed his duties in a competent manner.” 10 State v. Stallings, 658 N.W.2d 106, 109 (Iowa 2003).

2009With respect to the first prong of the test, “counsel’s performance is measured against the standard of a reasonably competent practitioner, with the 1In assessing a waiver, the court should inquire into the defendant’s understanding of the difference between jury and nonjury trials by informing the defendant that: “(1) twelve members of the community compose a jury; (2) the defendant may take part in jury selection; (3) jury verdicts must be unanimous; and (4) the court alone decides guilt or innocence if the defendant waives a jury trial.” State v. Stallings, 658 N.W.2d 106, 110 (Iowa 2003)

2020The second prong—prejudice—results when “there is a reasonable probability that, but for the counsel’s unprofessional errors, the result of the proceeding would have been different.” State v. Brown, 930 N.W.2d 840, 855 (Iowa 2019) (citations omitted).

2019The second prong—prejudice— results when “there is a reasonable probability that, but for the counsel’s unprofessional errors, the result of the proceeding would have been different.” State v. Brown, 930 N.W.2d 840, 855 (Iowa 2019) (internal citations omitted).

2019We approach the first prong with the presumption counsel performed her duties competently; “we measure counsel’s performance against the standard of a reasonably competent practitioner.” State v. Maxwell, 743 N.W.2d 185, 195 (Iowa 2008).

2019We approach the first prong with the presumption counsel performed her duties competently; "we measure counsel's performance against the standard of a reasonably competent practitioner." State v. Maxwell , 743 N.W.2d 185 , 195 (Iowa 2008).

2019Analysis To establish the first prong of his claim, Doornink must show counsel “performed below the standard demanded of a reasonably competent attorney.” Ledezma v. State, 626 N.W.2d 134, 142 (Iowa 2001).

2017M 6 To establish the first prong of the test, the defendant must be able to demonstrate that counsel performed “below the standard demanded of a reasonably competent attorney.” Ledezma v. State, 626 N.W.2d 134, 142 (Iowa 2001).

2019Although not required to predict changes in the law, “counsel must ‘exercise reasonable diligence in deciding whether an issue is “worth raising.” ’ ” State v. Dudley, 766 N.W.2d 606, 620 (Iowa 2009) (quoting State v. Westeen, 591 N.W.2d 203, 210 (Iowa 1999)).

2019Although not required to predict changes in the law, "counsel must 'exercise reasonable diligence in deciding whether an issue is "worth raising." ' " State v. Dudley , 766 N.W.2d 606 , 620 (Iowa 2009) (quoting State v. Westeen , 591 N.W.2d 203 , 210 (Iowa 1999) ).

2009The first prong of the test requires counsel's performance to be measured "`against the standard of a reasonably competent practitioner with the presumption that the attorney performed his duties in a competent manner.'" State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004) (quoting State v. Begey, 672 N.W.2d 747, 749 (Iowa 2003)). "[I]n order to satisfy the `prejudice' requirement, the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial." Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct.

2009The first prong of the test requires counsel's performance to be measured "`against the standard of a reasonably competent practitioner with the presumption that the attorney performed his duties in a competent manner.'" State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004) (quoting State v. Begey, 672 N.W.2d 747, 749 (Iowa 2003)). "[I]n order to satisfy the `prejudice' requirement, the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial." Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct.

2009The first prong of the test requires counsel's performance to be measured "`against the standard of a reasonably competent practitioner with the presumption that the attorney performed his duties in a competent manner.'" State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004) (quoting State v. Begey, 672 N.W.2d 747, 749 (Iowa 2003)). "[I]n order to satisfy the `prejudice' requirement, the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial." Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct.

2009The first prong of the test requires counsel’s performance to be measured “ ‘against the standard of a reasonably competent 5 practitioner with the presumption that the attorney performed his duties in a competent manner.’ ” State v. Dalton, 674 N.W.2d 111, 119 (Iowa 2004) (quoting State v. Begey, 672 N.W.2d 747, 749 (Iowa 2003)). “[I]n order to satisfy the ‘prejudice’ requirement, the defendant must show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 , 106 S.

1998This requires a showing “that counsel made errors so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Saadiq v. State, 387 N.W.2d 315, 325 (Iowa 1986) (quoting Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052, 2064 , 80 L.Ed.2d 674, 693 (1984)).

1998This requires a showing "that counsel made errors so serious that counsel was not functioning as the `counsel' guaranteed the defendant by the Sixth Amendment." Saadiq v. State, 387 N.W.2d 315, 325 (Iowa 1986) (quoting Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052, 2064 , 80 L.Ed.2d 674, 693 (1984)).

1983Rush v. Ray, 332 N.W.2d 325, 326 (Iowa 1983).

1983Rush v. Ray, 332 N.W.2d 325, 326 (Iowa 1983).

2018See State v. Clay , 824 N.W.2d 488 , 495 (Iowa 2012).

2014“Prejudice exists where the claimant proves by ‘a reasonable probability that, but for the counsel’s unprofessional errors, the result of the proceeding would have been different.’” State v. Clay, 824 N.W.2d 488 , 496 7 (Iowa 2012) (citation omitted).

2020See State v. Bergmann, 633 N.W.2d 328, 338 (Iowa 2001) (“Several cases have concluded that a reliable drug dog alert alone is enough to establish probable cause to search.”).

2020Thus, under our current law, a party may satisfy the standing test by showing a “legal interest” in the subject matter of the litigation and demonstrating the challenged decision has a specific and injurious effect on that “legal interest.” In our caselaw, we did not permit the federal zone-of-interest test articulated in Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 153 , 90 S. Ct. 827, 830 (1970), to limit standing in challenges to agency action.

2020Thus, under our current law, a party may satisfy the standing test by showing a “legal interest” in the subject matter of the litigation and demonstrating the challenged decision has a specific and injurious effect on that “legal interest.” In our caselaw, we did not permit the federal zone-of-interest test articulated in Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 153 , 90 S. Ct. 827, 830 (1970), to limit standing in challenges to agency action.

2020The district court is required to inform a defendant “of all direct consequences of the plea in the colloquy or in any written waiver thereof.” State v. Fisher, 877 N.W.2d 676, 682 (Iowa 2016).

2019See Kennedy, 601 N.W.2d at 64 .

2018See Ryan v. Arneson , 422 N.W.2d 491 , 495 (Iowa 1988).

2018See Ryan v. Arneson, 422 N.W.2d 491, 495 (Iowa 1988).