first element test (Iowa) · Go Syfert
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first element test in Iowa

7 Iowa opinions name it 2 courts 1984–2024 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 (4)

CaseFollowedCited
Hill v. Lockhartgreen
scotus · 1985 · cited in 2 Iowa opinions naming this issue, 2023–2024
2 sentences

2024On the second element, prejudice in the context of a guilty plea means “a reasonable probability that, but for counsel’s errors, [the applicant] would not have pleaded guilty and would have insisted on going to trial.” Doss v. State, 961 N.W.2d 701 , 709 (Iowa 2021) (citation omitted); see Hill v. Lockhart, 474 U.S. 52 , 57–59 (1985).

2023On the second element, prejudice in the context of a guilty plea 7 means “a reasonable probability that, but for counsel’s errors, [the defendant or postconviction applicant] would not have pleaded guilty and would have insisted on going to trial.” Doss, 961 N.W.2d at 709 (citation omitted); Hill v. Lockhart, 474 U.S. 52 , 57–59 (1985).

12
Plotner v. AT & T Corp.green
ca10 · 2000 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Cf. Plotner v. AT&T Corp., 224 F.3d 1161, 1169 (10th Cir. 2000) (“The law firm defendants appear by virtue of their activities as representatives of Green and AT & T, also creating privity.”).

11
Taylor v. Stategreen
iowa · 1984 · cited in 1 Iowa opinions naming this issue, 1990–1990
1 sentence

1990Taylor v. State, 352 N.W.2d 683, 685 (Iowa 1984).

11
City of Des Moines v. Public Employment Relations Boardgreen
iowa · 1979 · cited in 1 Iowa opinions naming this issue, 1984–1984
1 sentence

1984The specific interest actually required, however, is merely an interest “distinguished from a general interest, such as is the concern of all members of the community as a whole.” City of Des Moines v. Public Employment Relations Board, 275 N.W.2d 753, 759 (Iowa 1979).

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
Irving v. State green
iowa · 1995
2 sentences

2024“To establish the first element of the test, the [postconviction applicant] must overcome the presumption that the counsel was competent and demonstrate that, when considering the totality of the circumstances, the counsel’s performance was not within the normal range of competency.” Id.

2023“To establish the first element of the test, the defendant must overcome the presumption that the counsel was competent and demonstrate that, when considering the totality of the circumstances, the counsel’s performance was not within the normal range of competency.” Id.

22023–2024
State of Iowa v. Allen Bradley Clay green
iowa · 2012
1 sentence

2018However, our supreme court has found "an ethical violation [does not] always mean that ineffective assistance has [ ] occurred." State v. Clay , 824 N.W.2d 488 , 502 (Iowa 2012).

12018–2018
Brewer v. State green
iowa · 1989
1 sentence

1995Buck, 510 N.W.2d at 853 ; Brewer, 444 N.W.2d at 83 .

11995–1995
State v. Buck green
iowa · 1994
1 sentence

1995Buck, 510 N.W.2d at 853 ; Brewer, 444 N.W.2d at 83 .

11995–1995

Where else courts name it

TX 56 (1990–2025) CA 23 (1956–2025) IL 19 (1987–2025) OH 18 (2002–2025) TN 16 (1998–2019) MI 15 (2015–2025) MO 14 (1983–2024) WA 14 (1970–2019) WI 13 (1980–2025) NC 13 (1990–2025) PA 12 (1990–2026) UT 11 (1986–2026) NJ 10 (1993–2026) DE 9 (1987–2023) KS 9 (2019–2025) NY 8 (1990–2025) CO 8 (1983–2026) SD 7 (1978–2026) IA 7 (1984–2024) MA 7 (1992–2020) FL 7 (1988–2026) CT 7 (1991–2025) GA 6 (2002–2019) NM 6 (2013–2022) MN 6 (1987–2018) RI 6 (1980–2021) IN 6 (1982–2005) ID 6 (1993–2020) NE 5 (1959–2025) WV 5 (1988–2017) AR 4 (2002–2020) MT 4 (1994–2025) MS 4 (1994–2002) KY 4 (2013–2024) DC 4 (1986–2025) LA 3 (2001–2015) MD 3 (2002–2017) AL 3 (1995–2009) WY 3 (2003–2016) SC 3 (2003–2018) HI 3 (1978–2016) ME 3 (2001–2019) ND 2 (1982–2025) AZ 2 (1976–2006) OK 2 (1985–1993)

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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