49 Iowa opinions name it 2 courts 2004–2025 8 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.
| Case | Followed | Cited |
|---|---|---|
State of Iowa v. Robin Eugene Brubakergreen2 sentences2021See State v. Brubaker, 805 N.W.2d 164, 171 (Iowa 2011) (noting counsel does not provide ineffective assistance by failing to pursue a meritless claim). 2018See State v. Brubaker, 805 N.W.2d 164, 171 (Iowa 2011) (noting counsel cannot be faulted for declining to pursue a meritless claim). | 19 | 19 |
State of Iowa v. Demetrice De'angelo Tompkinsgreen2 sentences2025This flows from the general principle, restated in Ruiz and 6 other cases, that “[p]ostconviction counsel has no duty to pursue a meritless claim.” Chandler v. State, No. 24-0399, 2025 WL 2237244 , at *2 (Iowa Ct. App. Aug. 6, 2025) (citing Ruiz, 18 N.W.3d at 459); see also State v. Tompkins, 859 N.W.2d 631, 637 (Iowa 2015) (“[W]here a claimant alleges counsel’s failure to pursue a particular course breached an essential duty, there is no such duty when the suggested course would have been meritless.”). 2017Because counsel cannot be ineffective for failing to make a meritless claim,1 see Tompkins, 859 N.W.2d at 637 , Melendez’s ineffective-assistance claim necessarily fails. | 3 | 4 |
Phuoc Nguyen v. State of Iowagreen2 sentences2018See also Nguyen , 878 N.W.2d at 754 (noting PCR counsel has "no duty to pursue a meritless claim"). 2016See Nguyen v. State, 878 N.W.2d 744, 754 (Iowa 2016) (“[P]ostconviction counsel had no duty to pursue a meritless claim.”). | 3 | 3 |
State of Iowa v. Curtis Vance Halversongreen2 sentences2018See State v. Halverson, 857 N.W.2d 632, 635 (Iowa 2015). 2016Halverson, 857 N.W.2d at 635 . 16 Additionally, in 2013, we remanded Nguyen’s case to specifically address the question of “whether retroactive application of Heemstra is required by the equal protection, due process, and separation of powers clauses of the Iowa Constitution, or the Equal Protection Clause of the United States Constitution.” Nguyen, 829 N.W.2d at 189 . | 2 | 5 |
State of Iowa v. Andrew James Lopezgreen2 sentences2025See State v. Lopez, 872 N.W.2d 159, 169 (Iowa 2015). 2016State v. Lopez, 872 N.W.2d 159, 169 (Iowa 2015) (“Counsel does not fail to perform an essential duty by failing to raise a meritless objection.”). | 2 | 2 |
State of Iowa v. Andrew William Schlachtergreen2 sentences2022“Counsel is not ineffective for failing to make a meritless claim.” State v. Schlachter, 884 N.W.2d 782, 785 (Iowa Ct. App. 2016). 2019See State v. Schlachter, 884 N.W.2d 782, 785 (Iowa Ct. App. 2016) (“Counsel is not ineffective for failing to make a meritless claim”). | 2 | 2 |
State v. Dudleygreen2 sentences2017See State v. Dudley, 766 N.W.2d 606, 620 (Iowa 2009). 3 With respect to the suppression motion, Pargo has not proved a breach of duty. 2015State v. Dudley, 766 N.W.2d 606, 620 (Iowa 2009). | 2 | 2 |
State v. Schaergreen2 sentences2017State v. Schaer, 757 N.W.2d 630, 637 (Iowa 2008) (“Counsel has no duty to raise an issue or make an objection that has no merit.”). 2017See Schaer, 757 N.W.2d at 637 . | 2 | 2 |
State of Iowa v. Anthony George Brotherngreen2 sentences2014State v. Brothern, 832 N.W.2d 187, 192 (Iowa 2013). 2014State v. Brothern, 832 N.W.2d 187, 192 (Iowa 2013). | 2 | 2 |
Dunbar v. Stategreen1 sentence2025Ruiz v. State, 18 N.W.3d 453, 459 (Iowa 2025); Nguyen v. State, 878 N.W.2d 744, 754 (Iowa 2016). 5 As for Chandler’s second contention—that PCR counsel failed “to properly argue the sufficiency of newly discovered evidence”—we question whether this amounts to anything more than a complaint that “counsel should have done a better job.” Dunbar v. State, 515 N.W.2d 12, 15 (Iowa 1994) (explaining such an allegation is not enough to establish ineffective assistance). | 1 | 1 |
State v. Gravesgreen1 sentence2025State v. Graves, 668 N.W.2d 860, 881 (Iowa 2003). | 1 | 1 |
State of Iowa v. Peter Leroy Vealgreen1 sentence2021See Lilly, 930 N.W.2d at 309 . | 1 | 1 |
Ledezma v. Stategreen1 sentence2020See Ledezma, 626 N.W.2d at 143 . | 1 | 1 |
State v. Carrollgreen1 sentence2020See State v. Carroll, 767 N.W.2d 638, 645 (Iowa 2009) (stating “counsel has no duty to pursue a meritless issue”). | 1 | 1 |
Fryer v. Stategreen1 sentence2017Fryer v. State, 325 N.W.2d 400, 414 (Iowa 1982). 5 Counsel has no obligation to make a meritless claim. | 1 | 1 |
State v. Fountaingreen1 sentence2017State v. Fountain, 786 N.W.2d 260, 263 (Iowa 2010). | 1 | 1 |
State of Iowa v. Orlando David Rodriguezgreen1 sentence2015See State v. Rodriguez, 804 N.W.2d 844, 849 (Iowa 2011); Holmes v. State, 775 N.W.2d 733, 737 (Iowa Ct. App. 2009). | 1 | 1 |
Holmes v. Stategreen1 sentence2015See State v. Rodriguez, 804 N.W.2d 844, 849 (Iowa 2011); Holmes v. State, 775 N.W.2d 733, 737 (Iowa Ct. App. 2009). | 1 | 1 |
State v. Fintelgreen1 sentence2014State v. Flintel, 689 N.W.2d 95, 104 (Iowa 2004). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Phuoc Thanh Nguyen v. State of Iowa
green
2 sentences2016Halverson, 857 N.W.2d at 635 . 16 Additionally, in 2013, we remanded Nguyen’s case to specifically address the question of “whether retroactive application of Heemstra is required by the equal protection, due process, and separation of powers clauses of the Iowa Constitution, or the Equal Protection Clause of the United States Constitution.” Nguyen, 829 N.W.2d at 189 . 2016Halverson, 857 N.W.2d at 635 . 16 Additionally, in 2013, we remanded Nguyen’s case to specifically address the question of “whether retroactive application of Heemstra is required by the equal protection, due process, and separation of powers clauses of the Iowa Constitution, or the Equal Protection Clause of the United States Constitution.” Nguyen, 829 N.W.2d at 189 . | 2 | 2016–2016 |
State v. Liddell
green
1 sentence2004Id.; Liddell, 672 N.W.2d at 811 . | 1 | 2004–2004 |
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.
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.