5 Iowa opinions name it 2 courts 1980–2025 3 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. James Allen Wehrgreen2 sentences2025The defendant must ‘voluntarily and intelligently’ elect to conduct his own defense and most courts require him to do so in a timely manner.” State v. Wehr, 852 N.W.2d 495, 499 (Iowa Ct. App. 2014) (quoting Martinez v. Court of Appeal of Cal., 528 U.S. 152 , 161–62 (2000)). “[T]he purpose of a Faretta inquiry is to establish a defendant 3 in a colloquy with Smith and then granted his request to represent himself but with stand-by counsel. 2025The defendant must ‘voluntarily and intelligently’ elect to conduct his own defense and most courts require him to do so in a timely manner.” State v. Wehr, 852 N.W.2d 495, 499 (Iowa Ct. App. 2014) (quoting Martinez v. Court of Appeal of Cal., 528 U.S. 152 , 161–62 (2000)). “[T]he purpose of a Faretta inquiry is to establish a defendant 3 in a colloquy with Smith and then granted his request to represent himself but with stand-by counsel. | 1 | 1 |
United States v. Bradley Pruchagreen1 sentence2021Burgdorf claims the district court’s colloquy in case No. SRCR030282 was “non-existent” and argues “[a]t a minimum, some type of Faretta inquiry should have been made as to Burgdorf’s request for self-representation.” We believe the circumstances surrounding Burgdorf’s request make the district court’s actions sufficient to find no error. “[T]he right to self-representation is not absolute.” United States v. Harlan, 960 F.3d 1089, 1093 (8th Cir. 2020) (quoting United States v. Prucha, 856 F.3d 1184, 1187 (8th Cir. 2017)). | 1 | 1 |
United States v. Roman Harlangreen1 sentence2021Burgdorf claims the district court’s colloquy in case No. SRCR030282 was “non-existent” and argues “[a]t a minimum, some type of Faretta inquiry should have been made as to Burgdorf’s request for self-representation.” We believe the circumstances surrounding Burgdorf’s request make the district court’s actions sufficient to find no error. “[T]he right to self-representation is not absolute.” United States v. Harlan, 960 F.3d 1089, 1093 (8th Cir. 2020) (quoting United States v. Prucha, 856 F.3d 1184, 1187 (8th Cir. 2017)). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Martinez v. Court of Appeal of California, Fourth Appellate District
green
2 sentences2025The defendant must ‘voluntarily and intelligently’ elect to conduct his own defense and most courts require him to do so in a timely manner.” State v. Wehr, 852 N.W.2d 495, 499 (Iowa Ct. App. 2014) (quoting Martinez v. Court of Appeal of Cal., 528 U.S. 152 , 161–62 (2000)). “[T]he purpose of a Faretta inquiry is to establish a defendant 3 in a colloquy with Smith and then granted his request to represent himself but with stand-by counsel. 2025The defendant must ‘voluntarily and intelligently’ elect to conduct his own defense and most courts require him to do so in a timely manner.” State v. Wehr, 852 N.W.2d 495, 499 (Iowa Ct. App. 2014) (quoting Martinez v. Court of Appeal of Cal., 528 U.S. 152 , 161–62 (2000)). “[T]he purpose of a Faretta inquiry is to establish a defendant 3 in a colloquy with Smith and then granted his request to represent himself but with stand-by counsel. | 1 | 2025–2025 |
State v. Cooley
green
2 sentences2024The State’s argument blurs the line between Willform’s “mental ability to understand the proceedings” which is the focus of a competency hearing, and the Faretta inquiry, which is necessary “to establish a defendant actually understands the significance and consequences of an uncoerced decision to proceed pro se.” See Cooley, 608 N.W.2d at 17 . 2024The State’s argument blurs the line between Willform’s “mental ability to understand the proceedings” which is the focus of a competency hearing, and the Faretta inquiry, which is necessary “to establish a defendant actually understands the significance and consequences of an uncoerced decision to proceed pro se.” See Cooley, 608 N.W.2d at 17 . | 1 | 2024–2024 |
Hannan v. State
green
1 sentence2021“The surrounding circumstances will determine the sufficiency of a colloquy.” Hannan, 732 N.W.2d at 53 . | 1 | 2021–2021 |
Godinez v. Moran
green
2 sentences2000Godinez, 509 U.S. at 401 n. 12, 113 S.Ct. at 2687 n. 12, 125 L.Ed.2d at 333 n. 12. 2000Godinez, 509 U.S. at 401 n. 12, 113 S.Ct. at 2687 n. 12, 125 L.Ed.2d at 333 n. 12. | 1 | 2000–2000 |
McDowell v. United States
green
2 sentences2000See McDowell v. United States, 484 U.S. 980 , 108 S.Ct. 478 , 98 L.Ed.2d 492 (1987) (White, J. dissenting in the Court’s denial of certiorari). 2000See McDowell v. United States, 484 U.S. 980 , 108 S.Ct. 478 , 98 L.Ed.2d 492 (1987) (White, J. dissenting in the Court’s denial of certiorari). | 1 | 2000–2000 |
Rawlings v. United States
green
2 sentences2000See McDowell v. United States, 484 U.S. 980 , 108 S.Ct. 478 , 98 L.Ed.2d 492 (1987) (White, J. dissenting in the Court’s denial of certiorari). 2000See McDowell v. United States, 484 U.S. 980 , 108 S.Ct. 478 , 98 L.Ed.2d 492 (1987) (White, J. dissenting in the Court’s denial of certiorari). | 1 | 2000–2000 |
Faretta v. California
green
2 sentences1980The Supreme Court noted that Faretta’s request to act as co-counsel had been rejected and that “[tjhroughout the subsequent trial, the judge required that Faretta’s defense be conducted only through the appointed lawyer from the public defender’s office.” 422 *208 U.S. at 810-11, 95 S.Ct. at 2529 , 45 L.Ed.2d at 568 . 1980The Supreme Court noted that Faretta’s request to act as co-counsel had been rejected and that “[tjhroughout the subsequent trial, the judge required that Faretta’s defense be conducted only through the appointed lawyer from the public defender’s office.” 422 *208 U.S. at 810-11, 95 S.Ct. at 2529 , 45 L.Ed.2d at 568 . | 1 | 1980–1980 |
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.