good cause standard in Iowa

2026See Rucker, 828 N.W.2d at 603 (“Because the substantive rights of a plaintiff can be at stake through the application of a statute of limitations, it is important that the good-cause standard under rule 1.302(5) not be applied too narrowly.”).

2026See Rucker v. Taylor, 828 N.W.2d 595, 603 (Iowa 2013) (“Because the substantive rights of a plaintiff can be at stake through the application of a statute of limitations, it is important that the good-cause standard under rule 1.302(5) not be applied too narrowly.”).

2016But the reason for the delay is not “evaluated entirely in a vacuum.” State v. Petersen, 288 N.W.2d 332, 335 (Iowa 1980) (explaining shortness of the period, failure of the defendant to demand a speedy trial, or absence of prejudice are legitimate considerations only insofar as they affect the strength of the reason for delay).

1981“When a statute is plain and its meaning is clear, courts are not permitted to search for meaning beyond its expressed terms.” State v. Sunclades, 305 N.W.2d 491, 494 (Iowa 1981). *694 State v. Petersen, 288 N.W.2d 332 (Iowa 1980), discussed the good cause requirement as it pertained to the right to speedy trial under Iowa R.Crim.P. 27(2)(b).

2025As Ellis acknowledged at oral argument, we are not free to rewrite that standard. 8 The key focus of the good-cause analysis is “the reason for the delay.” McNeal, 897 N.W.2d at 704 (citation omitted).

2020See, e.g., State v. McNeal, 897 N.W.2d 697, 704 (Iowa 2017) (describing that a good-cause inquiry in the context of speedy trial requirements under Iowa Rule of Criminal Procedure 2.33(2)(b) focuses on “the reason for the delay,” which involves considering the length of the delay, whether the defendant demanded a speedy trial, and whether the delay prejudiced the defendant (quoting State v. Winters, 690 N.W.2d 903, 908 (Iowa 2005))); Wilson v. Ribbens, 678 N.W.2d 417 , 420–23 (Iowa 2004) (stating that “good cause” to excuse failure of service pursuant to Iowa Rule of Civil Procedure 1.302 mean

2016See Nichols v. United States, ___ U.S. ___, ___, 136 S. Ct. 1113, 1118 , ___ L.

2016See Nichols v. United States, — U.S. ——, -, 136 S.Ct. 1113, 1118 , 194 L.Ed.2d 324 , - (2016) (applying plain meaning of federal- sex offender registry statute and declining “the Government’s invitation to add an extra clause”); In re Estate of Whalen, 827 N.W.2d 184, 194 (Iowa 2013) (“[W]e may not extend, enlarge, or otherwise change the meaning of a statute under the guise of construction.” (quoting In re Estate of Bockwoldt, 814 N.W.2d 215, 223 (Iowa 2012))).

2016Miller, 637 N.W.2d at 205 ; Petersen, 288 N.W.2d at 335 . “[I]f the reason for the delay is insufficient, other factors will not avoid dismissal.” Ennenga, 812 N.W.2d at 706 ; accord State v. O’Bryan, 522 N.W.2d 103, 106 (Iowa Ct. App. 1994).

2016Miller, 637 N.W.2d at 205 ; Petersen, 288 N.W.2d at 335 . “[I]f the reason for the delay is insufficient, other factors will not avoid dismissal.” Ennenga, 812 N.W.2d at 706 ; accord State v. O’Bryan, 522 N.W.2d 103, 106 (Iowa Ct.App.1994).

1997See In re Custody of S.E.G., 521 N.W.2d 357, 361-62 (Minn.1994); In re Adoption of Riffle, 277 Mont. 388 , 922 P.2d 510, 514 (1996).

1997See In re Custody of S.E.G., 521 N.W.2d 357, 361-62 (Minn.1994); In re Adoption of Riffle, 277 Mont. 388 , 922 P.2d 510, 514 (1996).

1997See In re Custody of S.E.G., 521 N.W.2d 357, 361-62 (Minn.1994); In re Adoption of Riffle, 271 Mont. 388, 922 P.2d 510, 514 (1996).

1997See In re Custody of S.E.G., 521 N.W.2d 357, 361-62 (Minn.1994); In re Adoption of Riffle, 277 Mont. 388 , 922 P.2d 510, 514 (1996).

2019Id. (including a good-cause exception for each time limit). 5 By our count, twenty-nine Iowa appellate decisions cite Campbell for its discussion of “good cause” to excuse the State’s failure to meet the deadlines in rule 2.33(2). 6 As noted in footnote 3, the Miller case cited by counsel in the motion to dismiss involved a ninety-day speedy trial issue. 637 N.W.2d at 204 .

2019Id. (including a good-cause exception for each time limit). 5 By our count, twenty-nine Iowa appellate decisions cite Campbell for its discussion of “good cause” to excuse the State’s failure to meet the deadlines in rule 2.33(2). 6 As noted in footnote 3, the Miller case cited by counsel in the motion to dismiss involved a ninety-day speedy trial issue. 637 N.W.2d at 204 .

2026See 4 Ennenga, 812 N.W.2d at 706 (noting “[o]ur precedents disfavor allowing generalized clerical difficulties to qualify as good cause for a delay,” but clerical difficulties “arising out of unique, nonrecurring events which create a particular scheduling problem” may factor into a good cause analysis).

2016Miller, 637 N.W.2d at 205 ; Petersen, 288 N.W.2d at 335 . “[I]f the reason for the delay is insufficient, other factors will not avoid dismissal.” Ennenga, 812 N.W.2d at 706 ; accord State v. O’Bryan, 522 N.W.2d 103, 106 (Iowa Ct. App. 1994).

2015Meier, 641 N.W.2d at 542 ; Crall, 714 N.W.2d at 620 .

2005Meier v. Senecaut, 641 N.W.2d 532, 542 (Iowa 2002).

2020See, e.g., State v. McNeal, 897 N.W.2d 697, 704 (Iowa 2017) (describing that a good-cause inquiry in the context of speedy trial requirements under Iowa Rule of Criminal Procedure 2.33(2)(b) focuses on “the reason for the delay,” which involves considering the length of the delay, whether the defendant demanded a speedy trial, and whether the delay prejudiced the defendant (quoting State v. Winters, 690 N.W.2d 903, 908 (Iowa 2005))); Wilson v. Ribbens, 678 N.W.2d 417 , 420–23 (Iowa 2004) (stating that “good cause” to excuse failure of service pursuant to Iowa Rule of Civil Procedure 1.302 mean

2013See id.

2020See, e.g., State v. McNeal, 897 N.W.2d 697, 704 (Iowa 2017) (describing that a good-cause inquiry in the context of speedy trial requirements under Iowa Rule of Criminal Procedure 2.33(2)(b) focuses on “the reason for the delay,” which involves considering the length of the delay, whether the defendant demanded a speedy trial, and whether the delay prejudiced the defendant (quoting State v. Winters, 690 N.W.2d 903, 908 (Iowa 2005))); Wilson v. Ribbens, 678 N.W.2d 417 , 420–23 (Iowa 2004) (stating that “good cause” to excuse failure of service pursuant to Iowa Rule of Civil Procedure 1.302 mean

2018The good-cause inquiry focuses on "only one factor: the reason for the delay." Id.

2016The principles related to a defendant’s right to speedy trial and the good cause exception were recently recited in State v. Taylor, 881 N.W.2d 72, 76-78 (Iowa 2016), and need not be recited here.

2016“The good-cause test under our speedy-trial rules relies only on one factor: the reason for the delay.” Taylor, 881 N.W.2d at 77 .

2025See 804 N.W.2d at 252 ; see also Treptow, 960 N.W.2d 5 at 103 (discussing the 2019 omnibus crime bill that added section 814.6’s good cause requirement).

2025See State v. Damme, 944 N.W.2d 98 , 100 (Iowa 2020) (“We hold that the good-cause requirement is satisfied in this context when the defendant appeals a sentence that was neither mandatory nor agreed to in the plea bargain.”). 4 determinative.” State v. McKeever, 276 N.W.2d 385, 387 (Iowa 1979).

2025See id.

2025See Mokhtarian v. GTE Midwest Inc., 578 N.W.2d 666 , 668–69 (Iowa 1998) (considering a lapse of time when no service attempts were made and no explanation given for the delay in the good cause analysis). 1 From the time she called off the process server on December 19, 2023, until contacting the sheriff, who served Hansen on April 4, 2024, the only thing the record discloses Littleton doing is filing the Arkansas process server’s affidavit of non-service and filing a motion for default judgment.

2024See State v. Damme, 944 N.W.2d 98 , 104–05 (Iowa 2020). 6 “[O]ur task on appeal is not to second guess the decision made by the district court, but to determine if it was unreasonable or based on untenable grounds.” Formaro, 638 N.W.2d at 725 .

2022However, our supreme court has long recognized a defendant may challenge a guilty plea without filing a motion in arrest of judgment if the district court did not “ensure the defendant understands the necessity of filing a motion to challenge a guilty plea and the consequences of a failure to do so.” State v. Loye, 670 N.W.2d 141, 150 (Iowa 2003); see also State v. West, 326 N.W.2d 316, 317 (Iowa 1982) (reaching the merits of the defendant’s guilty-plea challenge “because the trial court did not advise him pursuant to [current rule 2.8(2)(d)] that a failure to challenge the plea by motion in a

2022However, our supreme court has long recognized a defendant may challenge a guilty plea without filing a motion in arrest of judgment if the district court did not “ensure the defendant understands the necessity of filing a motion to challenge a guilty plea and the consequences of a failure to do so.” State v. Loye, 670 N.W.2d 141, 150 (Iowa 2003); see also State v. West, 326 N.W.2d 316, 317 (Iowa 1982) (reaching the merits of the defendant’s guilty-plea challenge “because the trial court did not advise him pursuant to [current rule 2.8(2)(d)] that a failure to challenge the plea by motion in a

2022Compare State v. Kirchoff, 452 N.W.2d 801 , 802–03 (Iowa 1990) (discussing nuances of the motion-in-arrest-of-judgment requirement in 1990), with 2019 Iowa Acts ch. 140 § 28 (prohibiting appeals as a matter of right from convictions where the defendant has pled guilty but allowing exceptions for class “A” felonies and “case[s] where the defendant establishes good cause” effective July 1, 2019). 7 Or if the defendant pled guilty to a class “A” felony. 15 Because Scott has not established good cause under section 814.6(1)(a)(3), his only remaining option is discretionary review under section 814

2022See State v. Damme, 944 N.W.2d 98 , 105 (Iowa 2020). 5 The State contests Jensen’s good cause to appeal his enhanced sentence because he did not move in arrest of judgment to challenge any deficiencies in the proceeding to establish his prior conviction.1 The State also advances a broader argument that Jensen failed to preserve error under State v. Harrington. 893 N.W.2d 36, 43 , 45–46 (Iowa 2017) (requiring courts to ensure a factual basis exists to support the admission of prior convictions and requiring offenders to preserve error on defects through a motion in arrest of judgment).

2021See Sherwin-Williams Co., 789 N.W.2d at 425 (noting that when the legislature defines a term, “the common law and dictionary definitions which may not coincide with the legislative definition must yield to the language of the legislature” (quoting Hornby v. State, 559 N.W.2d 23, 25 (Iowa 1997))).

2021See Sherwin-Williams Co., 789 N.W.2d at 425 (noting that when the legislature defines a term, “the common law and dictionary definitions which may not coincide with the legislative definition must yield to the language of the legislature” (quoting Hornby v. State, 559 N.W.2d 23, 25 (Iowa 1997))).

2021We address a good-cause standard that supports our conclusion that “nothing in [the Iowa ICWA] places maintaining the Indian culture above a child’s rights or safety.” J.L., 779 N.W.2d at 492 (holding the “narrow definition of good cause prohibiting the children from objecting to the motion to transfer based upon their best interests and introducing evidence of their best interests” violated the children’s substantive due process rights).