substantive legal claim (Iowa) · Go Syfert
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substantive legal claim in Iowa

8 Iowa opinions name it 2 courts 1983–2022 4 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
Kimmelman v. Morrisongreen
scotus · 1986 · cited in 3 Iowa opinions naming this issue, 2021–2021
2 sentences

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

33
Wright v. Stategreen
iowactapp · 2017 · cited in 3 Iowa opinions naming this issue, 2021–2021
2 sentences

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

33
Jason Wayne Rose v. Joan Palmateer, Superintendent, Oregon State Penitentiarygreen
ca9 · 2005 · cited in 3 Iowa opinions naming this issue, 2021–2021
2 sentences

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

2021See Kimmelman v. Morrison, 477 U.S. 365, 374 , 106 S. Ct. 2574 , 2582–83 (1986) (distinguishing between ineffective- assistance-of-counsel claim and underlying constitutional claim); Rose v. Palmateer, 395 F.3d 1108, 1112 (9th Cir. 2005) (“While [the ineffective- assistance claim and underlying constitutional claim are] admittedly related, they are distinct claims with separate elements of proof, and each claim should have been separately and specifically presented to the state courts.”); Wright v. State, No. 16–0275, 2017 WL 1401475, at *2 (Iowa Ct. App. Apr. 19, 2017) (noting a direct legal

33
State v. Dudleygreen
iowa · 2009 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022A claim of ineffective assistance of counsel is more than an error preservation device; it is a substantive legal claim with its own elements.”); State v. Dudley, 766 N.W.2d 606, 616 (Iowa 2009) (“If a plaintiff cannot show preliminarily that persons in the two classes are similarly situated, we have concluded the court need not determine whether there is a constitutionally adequate basis for the persons’ different treatment.”).

11
Gregory Baldwin v. City of Estherville, Iowa Matt Reineke, Individually and in His Official Capacity as an Officer of the Estherville Police Department and Matt Hellickson, Individually and in His Official Capacity as an Officer of the Estherville Police Departmentgreen
iowa · 2018 · cited in 1 Iowa opinions naming this issue, 2019–2019
2 sentences

2019Denying a remedy for unconstitutional prosecutorial misconduct is anathema to that tradition, as it “drives a stake in the heart of a substantive legal doctrine.” Baldwin II, 915 N.W.2d at 284 (Appel, J., dissenting).

2019Denying a remedy for unconstitutional prosecutorial misconduct is anathema to that tradition, as it "drives a stake in the heart of a substantive legal doctrine." Baldwin II , 915 N.W.2d at 284 (Appel, J., dissenting).

11
Abodeely v. Cavrasgreen
iowa · 1974 · cited in 1 Iowa opinions naming this issue, 1983–1983
1 sentence

1983This conclusion has reference to our holding in Abodeely v. Cavras, 221 N.W.2d 494, 497-98 (Iowa 1974) that when a vendor exercises a right of forfeiture against a defaulting vendee, the liability of the latter for the unpaid purchase money is extinguished.

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 (2)

CaseCitedYears
Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics green
scotus · 1971
2 sentences

2018In the words of Justice Harlan in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics , contemporary modes of thought at the time of the United States Constitutional Convention reflected "modes of jurisprudential thought which appeared to link 'rights' and 'remedies' in a 1:1 correlation." 403 U.S. 388 , 400 n.3, 91 S.Ct. 1999 , 2007 n.3, 29 L.Ed.2d 619 (1971) (Harlan, J., concurring in the judgment).

2018In the words of Justice Harlan in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics , contemporary modes of thought at the time of the United States Constitutional Convention reflected "modes of jurisprudential thought which appeared to link 'rights' and 'remedies' in a 1:1 correlation." 403 U.S. 388 , 400 n.3, 91 S.Ct. 1999 , 2007 n.3, 29 L.Ed.2d 619 (1971) (Harlan, J., concurring in the judgment).

12018–2018
Gray v. Bowers green
iowa · 1983
1 sentence

1988The Gray holding is based on “a substantive legal doctrine which is separate and distinct from the common law doctrine of election of remedies.” Id. at 324-25 .

11988–1988

Statutes the citing opinions construe

IA § Iowa Code § 814.7 (4) IA § Iowa Code § 453B.12 (3) IA § Iowa Code § 814.29 (3) IA § Iowa Code § 814.6 (3) IA § Iowa Code § 815.10 (3) IA § Iowa Code § 901.2 (3) IA § Iowa Code § 902.1 (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

NY 15 (1982–2016) TX 11 (2004–2024) IA 8 (1983–2022) CA 8 (1985–2023) IL 6 (2014–2022) OR 5 (1976–2023) FL 4 (2003–2023) NJ 4 (2015–2026) DC 3 (2003–2017) PA 3 (1996–2019) WA 3 (2009–2025) ME 2 (2019–2019) MO 2 (2011–2020) DE 2 (1997–2005) VT 2 (2020–2023) MI 2 (2021–2021)

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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