West claim in Iowa

2026Compare State v. Lumadue, 622 N.W.2d 302 , 304–05 (Iowa 2001) (finding the sentencing court abused its discretion by using boilerplate language that read, “The court has determined that this sentence will provide reasonable protection of the public.

2026See id.

2022Thus, we review claims of ineffective 1The appeal resolved West’s claim that his counsel was ineffective for failing to object to the admissibility of recordings of a 911 call. 3 assistance of counsel de novo.” Lamasters v. State, 821 N.W.2d 856, 862 (Iowa 2012) (quotation marks and internal citations omitted).

2019See Meier v. Senecaut, 641 N.W.2d 532, 543 (Iowa 2002) (stating rule “requires the plaintiff to take affirmative action to obtain an extension or directions from the court if service cannot be accomplished”); Oetken v. Guerrero, No. 07- 2091, 2008 WL 4308134, at *2 (Iowa Ct. App. Sept. 17, 2008) (presupposing “timely motion for extension of [t]he service deadline”).

2019See Meier v. Senecaut, 641 N.W.2d 532, 543 (Iowa 2002) (stating rule “requires the plaintiff to take affirmative action to obtain an extension or directions from the court if service cannot be accomplished”); Oetken v. Guerrero, No. 07- 2091, 2008 WL 4308134, at *2 (Iowa Ct. App. Sept. 17, 2008) (presupposing “timely motion for extension of [t]he service deadline”).

2018See In re Det. of Betsworth, 711 N.W.2d 280, 286 (Iowa 2006).

2015See State v. Romer, 832 N.W.2d 169, 179 (Iowa 2013) (focusing on whether language of statute prohibited certain undisputed conduct); see also State v. West, No. 06-1316, 2007 WL 2963990, at *4 (Iowa Ct. App. Oct. 12, 2007) (noting West’s claim on his motion for judgment of acquittal turned on a statutory interpretation issue); State v. Wiley, No. 01-1458, 2002 WL 31309923 , at *2 (Iowa Ct. App. Oct. 16, 2002) (“Although the issue before us is cast as whether there was sufficient evidence to sustain a conviction . . . we believe the issue can at least as readily be viewed as a challenge to the

2015See State v. Romer, 832 N.W.2d 169, 179 (Iowa 2013) (focusing on whether language of statute prohibited certain undisputed conduct); see also State v. West, No. 06-1316, 2007 WL 2963990, at *4 (Iowa Ct. App. Oct. 12, 2007) (noting West’s claim on his motion for judgment of acquittal turned on a statutory interpretation issue); State v. Wiley, No. 01-1458, 2002 WL 31309923 , at *2 (Iowa Ct. App. Oct. 16, 2002) (“Although the issue before us is cast as whether there was sufficient evidence to sustain a conviction . . . we believe the issue can at least as readily be viewed as a challenge to the

1995See Triplett v. Azordegan, 570 F.2d 819 , 823-24 (8th Cir.1978) (it is the nature of the act performed by a state official not the status of the official as such that is determinative of the application of § 1983).