historical framework (Iowa) · Go Syfert
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historical framework in Iowa

7 Iowa opinions name it 2 courts 2001–2025 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 (5)

CaseFollowedCited
Ziglar v. Abbasigreen
scotus · 2017 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Most recently, in Ziglar v. Abbasi , Justice Thomas observed that "we have diverged from the historical inquiry mandated by the statute." 582 U.S. ----, ----, 137 S.Ct. 1843 , 1871, 198 L.Ed.2d 290 (2017) (Thomas, J., concurring in part and concurring in the judgment).

2018Most recently, in Ziglar v. Abbasi , Justice Thomas observed that "we have diverged from the historical inquiry mandated by the statute." 582 U.S. ----, ----, 137 S.Ct. 1843 , 1871, 198 L.Ed.2d 290 (2017) (Thomas, J., concurring in part and concurring in the judgment).

11
Snively v. Jabergreen
wash · 1956 · cited in 1 Iowa opinions naming this issue, 2007–2007
1 sentence

2007While we have no quarrel with the author’s historical analysis, we choose to refer to the two rules by the names ascribed to them by other American courts. 12 N.W. 487 , 488-89 (Mich. 1919); Snively v. Jaber, 296 P.2d 1015, 1019 (Wash. 1956).

11
Doe v. Raygreen
iowa · 1977 · cited in 1 Iowa opinions naming this issue, 2005–2005
2 sentences

2005Singer, Statutes and Statutory Construction § 49:01, at 8-9 (2000 rev.) [hereinafter Singer] (stating courts must consider the historical framework of a statute); see also Doe v. Ray, 251 N.W.2d 496, 501 (Iowa 1977) (“[I]n construing a statute we must be mindful of the state of the law when it was enacted .... ” (citing Egan v. Naylor, 208 N.W.2d 915, 918 (Iowa 1973))).

2005Singer, Statutes and Statutory Construction § 49:01, at 8-9 (2000 rev.) [hereinafter Singer] (stating courts must consider the historical framework of a statute); see also Doe v. Ray, 251 N.W.2d 496, 501 (Iowa 1977) ("[I]n construing a statute we must be mindful of the state of the law when it was enacted. . . ." (citing Egan v. Naylor, 208 N.W.2d 915, 918 (Iowa 1973))).

11
Davis v. Stategreen
iowa · 2004 · cited in 1 Iowa opinions naming this issue, 2005–2005
2 sentences

2005Accordingly, we “tak[e] into consideration the historical framework” of the statute, 2B Statutes and Statutory Construction § 49:01, at 8-9, and look to the state of the law existing at the time the statute was adopted, Davis v. State, 682 N.W.2d 58, 61 (Iowa 2004).

2005Accordingly, we "tak[e] into consideration the historical framework" of the statute, 2B Statutes and Statutory Construction § 49:01, at 8-9, and look to the state of the law existing at the time the statute was adopted, Davis v. State, 682 N.W.2d 58, 61 (Iowa 2004).

11
Egan v. Naylorgreen
iowa · 1973 · cited in 1 Iowa opinions naming this issue, 2005–2005
2 sentences

2005Singer, Statutes and Statutory Construction § 49:01, at 8-9 (2000 rev.) [hereinafter Singer] (stating courts must consider the historical framework of a statute); see also Doe v. Ray, 251 N.W.2d 496, 501 (Iowa 1977) (“[I]n construing a statute we must be mindful of the state of the law when it was enacted .... ” (citing Egan v. Naylor, 208 N.W.2d 915, 918 (Iowa 1973))).

2005Singer, Statutes and Statutory Construction § 49:01, at 8-9 (2000 rev.) [hereinafter Singer] (stating courts must consider the historical framework of a statute); see also Doe v. Ray, 251 N.W.2d 496, 501 (Iowa 1977) ("[I]n construing a statute we must be mindful of the state of the law when it was enacted. . . ." (citing Egan v. Naylor, 208 N.W.2d 915, 918 (Iowa 1973))).

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
United States v. Raymon Doug Risner green
ca6 · 2025
2 sentences

2025While we acknowledge that Mehner and Brecunier are not controlling because they pre-date Heller and Bruen and thus do not feature an adequate historical analysis, see Risner, 129 F.4th at 366–67 (noting that the first step of the historical analysis post-Heller was “embrace[d]” by the Supreme Court in Bruen, but pre-Heller cases may have used a different mode of analysis), nothing in Bruen undermines their holdings.

2025While we acknowledge that Mehner and Brecunier are not controlling because they pre-date Heller and Bruen and thus do not feature an adequate historical analysis, see Risner, 129 F.4th at 366–67 (noting that the first step of the historical analysis post-Heller was “embrace[d]” by the Supreme Court in Bruen, but pre-Heller cases may have used a different mode of analysis), nothing in Bruen undermines their holdings.

12025–2025
Williams v. New York green
scotus · 1949
2 sentences

2018The historical rule is supported by “sound practical reasons.” Id.

2018For criminal trials, courts have fashioned rules of evidence that “narrowly confine the trial contest to evidence that is strictly relevant to the particular offense charged.” Id. at 247 .

12018–2018
cluster 371446 green
· 1979
2 sentences

2003Id. (footnotes omitted).

2003In re U.S. Financial Securities, 609 F.2d at 425 .

12003–2003
Troxel v. Granville green
scotus · 2000
2 sentences

2001Id. at 68-69 , 120 S.Ct. at 2061-62 , 147 L.Ed.2d at 58-59 .

2001Id. at 68-69 , 120 S.Ct. at 2061-62 , 147 L.Ed.2d at 58-59 .

12001–2001

Where else courts name it

CA 85 (1962–2026) OR 83 (1945–2025) IL 57 (1978–2026) WA 38 (1984–2026) TX 32 (1971–2025) MI 27 (1971–2025) UT 27 (1991–2025) NJ 26 (1964–2024) WI 26 (1976–2022) PA 25 (1973–2024) CT 22 (1974–2017) NM 21 (1982–2025) FL 20 (1959–2025) NY 18 (1881–2023) IN 18 (1984–2025) GA 16 (1986–2025) OH 16 (1996–2025) MD 13 (1949–2022) LA 10 (1955–2016) AZ 10 (1970–2012) KS 9 (1968–2026) MO 9 (1988–2018) NC 9 (1976–2025) DE 8 (1977–2025) OK 8 (1958–2008) CO 8 (1987–2014) IA 7 (2001–2025) WV 7 (1974–2017) VA 7 (1996–2025) DC 7 (1980–2026) VT 6 (1988–2021) SC 6 (1984–2021) AR 5 (1988–2019) MN 5 (1991–2023) RI 5 (1981–2017) MT 4 (2016–2024) WY 4 (1990–2007) KY 4 (1978–2026) ID 4 (1976–2008) NV 3 (1989–2024) TN 3 (1994–2022) AL 3 (1993–1996) MA 3 (2012–2025) MS 3 (1985–1993) HI 3 (1982–2005) ME 3 (1976–2022) SD 2 (2009–2020) ND 2 (1980–1986) VI 2 (1979–2015) NH 2 (2004–2019)

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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