Iowa Code » Chapter 814 — APPEALS FROM THE DISTRICT COURT
Iowa Code

Iowa Code § 814.6A (2026)

Pro se filings by defendant currently represented by counsel

✓ current as of July 2026
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1. Except as otherwise provided in subsection 3, a defendant who is currently represented by counsel shall not file any pro se document, including a brief, reply brief, or motion, in any Iowa court. The court shall not consider, and opposing counsel shall not respond to, such pro se filings.

2. This section does not prohibit a defendant from proceeding without the assistance of counsel.

3. A defendant currently represented by counsel may file the following pro se documents:

a. A pro se motion seeking disqualification of the counsel, which a court may grant upon a showing of good cause.

b. A pro se notice of appeal.

c. A pro se response to a motion to withdraw pursuant to rule of appellate procedure 6.1005. 2019 Acts, ch 140, §30; 2022 Acts, ch 1110, §1 See also §822.3A \n

Notes of Decisions
Cited in 64 cases (43 in the last 5 years), 2019–2026 · leading case: State of Iowa v. Howard J. Thompson (Iowa 2021).
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State of Iowa v. Howard J. Thompson (Iowa 2021). · cites it 38× “The State requested the clerk of the supreme court strike Thompson’s pro se supplemental brief pursuant to section 814.6A. We ordered the motion and resistance be submitted with this appeal and ordered the parties to brief the issue.”
State of Iowa v. Howard J. Thompson (Iowa 2021). · cites it 38× “The State requested this court strike Thompson’s pro se supplemental brief pursuant to section 814.6A. We ordered the motion and resistance be submitted with this appeal and ordered the parties to brief the issue.”
State of Iowa v. George Davis (Iowa 2022). · cites it 32× “This timely notice of appeal was certified by the clerk of court on September 14. On September 14, Davis’s plea counsel moved to withdraw from the case.”
State of Iowa v. Korki Ricoh Wilbourn (Iowa 2022). · cites it 18× “He filed a pro se notice of appeal while represented by counsel notwithstanding Iowa Code section 814.6A (prohibiting pro se filings by represented parties), and his appellate attorney’s subsequent notice of appeal was untimely.”
State of Iowa v. Korki Ricoh Wilbourn (Iowa 2022). · cites it 18× “He filed a pro se notice of appeal while represented by counsel notwithstanding Iowa Code section 814.6A (prohibiting pro se filings by represented parties), and his appellate attorney’s subsequent notice of appeal was untimely.”
State of Iowa v. Veil Jacoby Jackson-Douglass (Iowa 2022). · cites it 16× “In light of section 814.6A and plea counsel’s failure to timely file a notice of appeal, we had concerns regarding this court’s jurisdiction over Jackson- Douglass’s appeal.”
John Lee Hrbek v. State of Iowa (Iowa 2021). · cites it 12× “In this specific context, we hold section 814.6A, as applied to prohibit the filing of pro se supplemental briefs on appeal, does not violate any aspect of the separation-of-powers doctrine.”
State of Iowa v. Dantreon Levon Newman (Iowa 2022). · cites it 12× “His pro se notice was a nullity from the outset by 14 application of Iowa Code section 814.6A. Yet ten days later and within the thirty-day deadline, on July 22, the district court entered an order that gave Newman and his lawyers every indication that the pro se notice of…”
State of Iowa v. Dantreon Levon Newman (Iowa 2022). · cites it 12× “His pro se notice was a nullity from the outset by application of Iowa 14 Code section 814.6A. Yet ten days later and within the thirty-day deadline, on July 22, the district court entered an order that gave Newman and his lawyers every indication that the pro se notice of…”
State of Iowa v. Randy Allen Crawford (Iowa 2022). · cites it 8× “The State contends that where, as here, a defendant was represented by counsel, section 814.6A renders the pro se notice of appeal a nullity without legal effect.”
State of Iowa v. Michael Kenneth Mitchell (Iowa Ct. App. 2023). · cites it 8× “Davis, our supreme court held that despite the potential prohibition Iowa Code section 814.6A imposes on courts considering pro se notices of appeal, appellate courts could grant delayed appeals following a pro se notice of appeal in appropriate circumstances.”
State of Iowa v. Maurice Dontez Daye (Iowa Ct. App. 2026). · cites it 8× “But because Daye was represented by counsel when he filed his pro se motion in arrest of judgment, the court properly concluded that Iowa Code section 814.6A prohibited the court from considering the motion.”
Show all 64 citing cases →
— Iowa Code § 814.6A(1) — 36 cases
State of Iowa v. Frankie Ray O'Connor (Iowa Ct. App. 2020).
State of Iowa v. Dantreon Levon Newman (Iowa 2022). “His pro se notice was a nullity from the outset by 14 application of Iowa Code section 814.6A. Yet ten days later and within the thirty-day deadline, on July 22, the district court entered an order that gave Newman and his lawyers every indication that the pro se notice of…”
State of Iowa v. Dantreon Levon Newman (Iowa 2022). “His pro se notice was a nullity from the outset by application of Iowa 14 Code section 814.6A. Yet ten days later and within the thirty-day deadline, on July 22, the district court entered an order that gave Newman and his lawyers every indication that the pro se notice of…”
State of Iowa v. Tait Otis Purk (Iowa Ct. App. 2019).
State of Iowa v. Dion Banks (Iowa Ct. App. 2020).
— Iowa Code § 814.6A(1)(a)(3) — 1 case
State of Iowa v. Jameesha Renae Allen (Iowa Ct. App. 2021).
— Iowa Code § 814.6A(3) — 1 case
Chester Howard Greenup v. State of Iowa (Iowa Ct. App. 2021).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.