materiality requirement (Iowa) · Go Syfert
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materiality requirement in Iowa

5 Iowa opinions name it 2 courts 2011–2026 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.

Followed or applied (3)

CaseFollowedCited
State v. Smithgreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026See State v. Smith, 573 N.W.2d 14, 22 (Iowa 1997) (finding “little chance the alleged newly-discovered evidence would have changed the result of the trial”). 15 IV.

11
Aguilera v. Stategreen
iowa · 2011 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024We consider the suppressed evidence collectively, not “item by item.” Aguilera v. State, 807 N.W.2d 249, 255 (Iowa 2011) (citing Kyles, 514 U.S. at 436–37).

11
Pennsylvania v. Ritchiegreen
scotus · 1987 · cited in 1 Iowa opinions naming this issue, 2020–2020
2 sentences

2020The harmless-error test reference in the Neiderbach footnote that Barrett cites was part of a quote from Pennsylvania v. Ritchie, 480 U.S. 39, 58 , 107 S. Ct. 989, 1002 (1987), in which the Supreme Court found a due process violation based on confidential records alleged to contain exculpatory information that were withheld from the defendant.

2020The harmless-error test reference in the Neiderbach footnote that Barrett cites was part of a quote from Pennsylvania v. Ritchie, 480 U.S. 39, 58 , 107 S. Ct. 989, 1002 (1987), in which the Supreme Court found a due process violation based on confidential records alleged to contain exculpatory information that were withheld from the defendant.

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
David R. Desimone v. State of Iowa green
iowa · 2011
2 sentences

2023Importantly, “the materiality requirement requires the court to assess the 8 Bahena also makes references to evidence potentially implicating Lowe in the disappearance of another child. 26 possible effects nondisclosure had on trial preparation and strategy, not merely the weight of the evidence.” Id.

2020Under this standard, the court asks whether there exists “a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” DeSimone, 803 N.W.2d at 105 (quoting Bagley, 473 U.S. at 682 , 105 S. Ct. at 3383 ).

22020–2023
Kyles v. Whitley green
scotus · 1995
1 sentence

2024We consider the suppressed evidence collectively, not “item by item.” Aguilera v. State, 807 N.W.2d 249, 255 (Iowa 2011) (citing Kyles, 514 U.S. at 436–37).

12024–2024
United States v. Bagley green
scotus · 1985
2 sentences

2020Under this standard, the court asks whether there exists “a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” DeSimone, 803 N.W.2d at 105 (quoting Bagley, 473 U.S. at 682 , 105 S. Ct. at 3383 ).

2020Under this standard, the court asks whether there exists “a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” DeSimone, 803 N.W.2d at 105 (quoting Bagley, 473 U.S. at 682 , 105 S. Ct. at 3383 ).

12020–2020
Strickler v. Greene green
scotus · 1999
2 sentences

2011Materiality requires a “reasonable probability” of a different trial outcome, not merely a “reasonable possibility.” Strickler, 527 U.S. at 291 , 119 S.Ct. at 1953 , 144 L.Ed.2d at 308 .

2011Materiality requires a “reasonable probability” of a different trial outcome, not merely a “reasonable possibility.” Strickler, 527 U.S. at 291 , 119 S.Ct. at 1953 , 144 L.Ed.2d at 308 .

12011–2011

Where else courts name it

TX 168 (1975–2026) CA 102 (1899–2026) DE 66 (1985–2026) IL 40 (1934–2026) PA 39 (1980–2026) MD 38 (1982–2025) VA 36 (1987–2026) NJ 28 (1963–2025) WA 25 (1983–2024) MI 22 (1971–2026) NY 22 (1851–2026) LA 20 (1982–2025) FL 19 (1985–2019) CO 18 (1983–2025) DC 17 (2001–2025) TN 17 (2000–2025) OH 17 (1987–2026) MO 17 (1986–2024) ID 14 (1985–2022) NC 14 (2006–2023) WI 13 (1978–2023) CT 11 (1960–2024) MN 9 (1982–2024) UT 8 (1991–2025) MS 8 (1987–2013) IN 8 (1988–2016) KS 8 (1961–2024) MA 8 (1985–2020) OR 8 (1985–2024) NV 6 (1994–2016) GA 6 (2021–2026) AL 5 (1989–2015) IA 5 (2011–2026) MT 5 (1998–2016) KY 5 (1982–2025) NE 4 (1998–2025) SC 4 (2004–2018) AZ 4 (1985–2018) SD 4 (2020–2025) HI 3 (2000–2023) ND 3 (1981–2016) WV 3 (1998–2018) WY 3 (1992–2025) RI 3 (1975–1998) VT 2 (1987–2001) NM 2 (1994–2025) ME 2 (2008–2013) OK 2 (2015–2015)

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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