use of a peremptory challenge (Iowa) · Go Syfert
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use of a peremptory challenge in Iowa

5 Iowa opinions name it 2 courts 2005–2021 1 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 (2)

CaseFollowedCited
State v. Neuendorfgreen
iowa · 1993 · cited in 2 Iowa opinions naming this issue, 2005–2021
2 sentences

2021The supreme court abandoned the “automatic reversal rule,” holding that an improper denial of a challenge for cause “is not automatically a ground for reversal when the juror in question has been removed through the use of a peremptory challenge.” Id. at 744 (overruling State v. Beckwith, 46 N.W.2d 20 (Iowa 1951), which reiterated that prejudice would be presumed if defendant was forced to use peremptory challenge to cure improper ruling on challenge for cause).

2005We are asked in connection with our consideration of that contention to abandon the legal proposition established in State v. Neuendorf, 509 N.W.2d 743, 747 (Iowa 1994), that the use of a peremptory challenge to remove an allegedly prejudiced juror from the array negates any prejudice that might otherwise arise from a denial of a challenge for cause.

22
State of Iowa v. Jerin Douglas Mootzgreen
iowa · 2012 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Cf. State v. Mootz, 808 N.W.2d 207, 226 (Iowa 2012) (“We therefore require automatic reversal whenever a defendant is denied the use of a peremptory challenge based on an erroneous interpretation of Batson and its progeny and the objectionable juror is improperly seated.”).2 We affirm the postconviction court’s denial of this ineffective-assistance-of- counsel claim.

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 (3)

CaseCitedYears
State v. Beckwith green
iowa · 1951
1 sentence

2021The supreme court abandoned the “automatic reversal rule,” holding that an improper denial of a challenge for cause “is not automatically a ground for reversal when the juror in question has been removed through the use of a peremptory challenge.” Id. at 744 (overruling State v. Beckwith, 46 N.W.2d 20 (Iowa 1951), which reiterated that prejudice would be presumed if defendant was forced to use peremptory challenge to cure improper ruling on challenge for cause).

12021–2021
United States v. Martinez-Salazar green
scotus · 2000
2 sentences

2017The Martinez-Salazar Court reemphasized the use of a peremptory challenge by the defendant was in line with its purpose, namely, “to help secure the constitutional guarantee of trial by an impartial jury.” Id. at 316 , 120 S.Ct. at 782 .

2017The Martinez-Salazar Court reemphasized the use of a peremptory challenge by the defendant was in line with its purpose, namely, “to help secure the constitutional guarantee of trial by an impartial jury.” Id. at 316 , 120 S.Ct. at 782 .

12017–2017
State v. Reed red
iowa · 1926
2 sentences

2012Id. at 1353-54, 208 N.W. at 309 .

2012Id. at 1353–54, 208 N.W. at 309 .

12012–2012

Where else courts name it

TX 36 (1988–2025) OH 26 (1997–2025) FL 25 (1994–2026) IN 19 (1990–2020) WA 18 (1976–2026) MA 17 (1991–2025) IL 13 (1990–2024) CA 9 (1988–2025) MN 9 (1985–2024) CO 8 (1992–2026) MO 7 (1974–2014) WI 6 (1998–2001) CT 6 (1995–2019) AR 6 (1984–2001) MI 5 (1989–2014) NV 5 (2018–2020) MS 5 (1991–2001) IA 5 (2005–2021) MD 4 (1989–1992) AL 4 (1990–2026) OR 4 (1990–2022) AZ 4 (1989–2003) NY 4 (1997–2019) TN 4 (2005–2021) KY 4 (1992–2024) LA 3 (1992–2006) UT 3 (1989–2002) GA 3 (1993–2003) NJ 2 (2019–2025) OK 2 (1995–2003) MT 2 (1999–2022) ID 2 (2018–2023) PA 2 (1989–1995) SC 2 (2000–2011) WV 2 (1995–2025)

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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