watershed rule (Iowa) · Go Syfert
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watershed rule in Iowa

5 Iowa opinions name it 2 courts 2012–2026 2 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 (6)

CaseFollowedCited
Teague v. Lanegreen
scotus · 1989 · cited in 2 Iowa opinions naming this issue, 2019–2020
2 sentences

2020Id. at 81–82 (quoting Teague, 489 U.S. at 315 , 109 S. Ct. at 1078 ).

2020Id. at 81–82 (quoting Teague, 489 U.S. at 315 , 109 S. Ct. at 1078 ).

12
Montgomery v. Louisianagreen
· 2016 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020See Montgomery, 577 U.S. at ___, 136 S. Ct. at 729 (clarifying that Teague’s rule that new substantive rules apply retroactively “is best understood as resting upon constitutional premises” but also reserving the question of the constitutional status of Teague’s watershed-rules exception for another day).

11
Schriro v. Summerlingreen
scotus · 2004 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019“This class of rules is extremely narrow, and ‘it is unlikely that any has yet to emerge.’” 6 Schriro v. Summerlin, 542 U.S. 348, 352 (2004) (altered for readability) (quoting Tyler v. Cain, 533 U.S. 656, 667, n.7 (2001)).

11
Tyler v. Caingreen
scotus · 2001 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019“This class of rules is extremely narrow, and ‘it is unlikely that any has yet to emerge.’” 6 Schriro v. Summerlin, 542 U.S. 348, 352 (2004) (altered for readability) (quoting Tyler v. Cain, 533 U.S. 656, 667, n.7 (2001)).

11
Rose v. Lundygreen
scotus · 1982 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019See Teague, 489 U.S. at 314 (providing examples of watershed rules as those that prevented “proceeding[s] . . . dominated by mob violence,” “prosecutor[s] knowingly ma[king] use of perjured testimony,” and convictions secured through “confession[s] extorted from the defendant by brutal methods” (quoting Rose v. Lundy, 455 U.S. 509, 544 (1982) (Stevens, J., dissenting))).

11
Figuereo-Sanchez v. United Statesgreen
ca11 · 2012 · cited in 1 Iowa opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Figuereo-Sanchez v. United States, 678 F.3d 1203 , 1209 (11th Cir.2012) (holding that “Padilla did not announce a watershed rule of criminal procedure”); see also United States v. Aceves, No. 10-00738, 2011 WL 976706 , *4 (D.Haw.

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
Gideon v. Wainwright green
scotus · 1963
2 sentences

2026The only case to ever be applied in such a fashion is Gideon v. Wainwright, 372 U.S. 335 , 344–45 (1963) (recognizing right to appointed counsel).

2022This is because McCoy is a refinement and extension of a presupposed watershed rule in Gideon v. Wainwright, 372 U.S. 335 (1963) and is not a watershed rule in and of itself.

22022–2026
Brewer v. State green
iowa · 1989
2 sentences

2020Id. at 81–82 (quoting Teague, 489 U.S. at 315 , 109 S. Ct. at 1078 ).

2019Id. at 81-82 .

22019–2020
Phillip Smith, II v. Josh Stein green
ca4 · 2020
1 sentence

2022Stein, 982 F.3d at 235 .

12022–2022

Statutes the citing opinions construe

IA § Iowa Code § 822.3 (5)

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.

Where else courts name it

PA 31 (2004–2024) CA 18 (2005–2022) IL 18 (2001–2019) TN 18 (2005–2019) MN 17 (2003–2025) WA 16 (2005–2025) CT 15 (2015–2025) CO 11 (2002–2026) NM 10 (2007–2023) KS 10 (2001–2021) ID 9 (2005–2023) NY 7 (2005–2024) LA 7 (1992–2023) AZ 6 (2001–2023) OH 6 (2006–2019) IA 5 (2012–2026) OR 5 (2004–2020) MI 5 (2014–2026) VT 4 (2007–2018) NJ 4 (2012–2026) WI 4 (2003–2025) SC 3 (2007–2015) GA 3 (2012–2018) MS 3 (1994–2006) TX 3 (2012–2015) MA 3 (2005–2023) ME 3 (2007–2017) MO 3 (2003–2015) AL 3 (2009–2015) WY 2 (2014–2014) NE 2 (2003–2014)

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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