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

Iowa Code § 814.7 (2026)

Ineffective assistance claim on appeal in a criminal case

✓ current as of July 2026
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An ineffective assistance of counsel claim in a criminal case shall be determined by filing an application for postconviction relief pursuant to chapter 822. The claim need not be raised on direct appeal from the criminal proceedings in order to preserve the claim for\n\nTue Dec 09 21:53:39 2025 Iowa Code 2026, Chapter 814 (26, 0) 3 APPEALS FROM THE DISTRICT COURT, §814.11\n\npostconviction relief purposes, and the claim shall not be decided on direct appeal from the criminal proceedings. 2004 Acts, ch 1017, §2; 2019 Acts, ch 140, §31

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Notes of Decisions
Cited in 487 cases (195 in the last 5 years), 2006–2026 · leading case: State v. Johnson, 784 N.W.2d 192 (Iowa 2010).
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State v. Johnson, 784 N.W.2d 192 (Iowa 2010). · cites it 28× “1017, § 2 (codified at Iowa Code § 814.7 (2005)). That section provides: 814.”
Hannan v. State, 732 N.W.2d 45 (Iowa 2007). · cites it 38× “Iowa Code § 814.7 (“The [ineffective assistance of counsel] claim need not be raised on direct appeal from the criminal proceedings in order to preserve the claim for postconvietion relief purposes.”
State v. Straw, 709 N.W.2d 128 (Iowa 2006). · cites it 8× “" Iowa Code § 814.7 (1) (2005). The defendant may raise the ineffective assistance claim on direct appeal if he or she has reasonable grounds to believe the record is adequate to address the claim on direct appeal.”
State of Iowa v. Anthony George Brothern, 832 N.W.2d 187 (Iowa 2013). · cites it 14× “” See Iowa Code § 814.7 (1). It further provides that a party “may, but is not required to, raise an ineffective assistance claim on direct appeal from the criminal proceedings.”
State v. Tate, 710 N.W.2d 237 (Iowa 2006). · cites it 10× “" Iowa Code § 814.7 (1) (2005). The defendant may raise the ineffective assistance claim on direct appeal if he or she "has reasonable *240 grounds to believe that the record is adequate to address the claim on direct appeal.”
State v. Bearse, 748 N.W.2d 211 (Iowa 2008). · cites it 8× “" Iowa Code § 814.7 (3). "Although claims of ineffective assistance of counsel are generally preserved for postconviction relief proceedings, we will consider such claims on direct appeal where the record is adequate.”
State of Iowa v. Jonathan Q. Adams, 810 N.W.2d 365 (Iowa 2012). · cites it 6× “Iowa Code § 814.7 (2) (2007). If we determine the record is adequate, we may resolve the claim.”
State v. Fountain, 786 N.W.2d 260 (Iowa 2010). · cites it 4× “Iowa Code § 814.7 (2) (2005); 1 State v. Lucas, 323 N.”
State of Iowa v. Max v. Thorndike, 860 N.W.2d 316 (Iowa 2015). · cites it 3× “” Iowa Code § 814.7 (1). However, a defendant may raise such a claim on direct appeal if he or she has “reasonable grounds to believe that the record is adequate to address the claim on direct appeal.”
State v. Bentley, 757 N.W.2d 257 (Iowa 2008). · cites it 4× “Iowa Code section 814.7(1) reheves defendants from the necessity of raising ineffective-assistance-of-counsel claims on direct appeal.”
Martin Shane Moon v. State of Iowa, 911 N.W.2d 137 (Iowa 2018). · cites it 2× “1017, § 2 (codified at Iowa Code § 814.7 (2005) ), as recognized in State v.”
State v. Cromer, 765 N.W.2d 1 (Iowa 2009). · cites it 5× “Iowa Code § 814.7 (2) (2009). When raised in a direct appeal, we can proceed to decide them if the record is adequate for our review.”
Show all 487 citing cases →
— Iowa Code § 814.7(1) — 7 cases
State v. Johnson, 784 N.W.2d 192 (Iowa 2010). “1017, § 2 (codified at Iowa Code § 814.7 (2005)). That section provides: 814.”
State v. Bentley, 757 N.W.2d 257 (Iowa 2008). “Iowa Code section 814.7(1) reheves defendants from the necessity of raising ineffective-assistance-of-counsel claims on direct appeal.”
Shawn Deshay Hoosman, Applicant-Appellant v. State of Iowa (Iowa Ct. App. 2016).
State of Iowa v. Eric Thompson (Iowa Ct. App. 2016).
State of Iowa v. Kyle Anthony Sadler (Iowa Ct. App. 2020).
— Iowa Code § 814.7(2) — 15 cases
State v. Straw, 709 N.W.2d 128 (Iowa 2006). “" Iowa Code § 814.7 (1) (2005). The defendant may raise the ineffective assistance claim on direct appeal if he or she has reasonable grounds to believe the record is adequate to address the claim on direct appeal.”
State v. Tate, 710 N.W.2d 237 (Iowa 2006). “" Iowa Code § 814.7 (1) (2005). The defendant may raise the ineffective assistance claim on direct appeal if he or she "has reasonable *240 grounds to believe that the record is adequate to address the claim on direct appeal.”
State of Iowa v. Anthony George Brothern, 832 N.W.2d 187 (Iowa 2013). “” See Iowa Code § 814.7 (1). It further provides that a party “may, but is not required to, raise an ineffective assistance claim on direct appeal from the criminal proceedings.”
State v. Johnson, 784 N.W.2d 192 (Iowa 2010). “1017, § 2 (codified at Iowa Code § 814.7 (2005)). That section provides: 814.”
State of Iowa v. Max v. Thorndike, 860 N.W.2d 316 (Iowa 2015). “” Iowa Code § 814.7 (1). However, a defendant may raise such a claim on direct appeal if he or she has “reasonable grounds to believe that the record is adequate to address the claim on direct appeal.”
— Iowa Code § 814.7(2020) — 1 case
State of Iowa v. Adam Benjamin Burkhead (Iowa Ct. App. 2020).
— Iowa Code § 814.7(3) — 26 cases
State v. Johnson, 784 N.W.2d 192 (Iowa 2010). “1017, § 2 (codified at Iowa Code § 814.7 (2005)). That section provides: 814.”
State v. Bearse, 748 N.W.2d 211 (Iowa 2008). “" Iowa Code § 814.7 (3). "Although claims of ineffective assistance of counsel are generally preserved for postconviction relief proceedings, we will consider such claims on direct appeal where the record is adequate.”
State v. Straw, 709 N.W.2d 128 (Iowa 2006). “" Iowa Code § 814.7 (1) (2005). The defendant may raise the ineffective assistance claim on direct appeal if he or she has reasonable grounds to believe the record is adequate to address the claim on direct appeal.”
State of Iowa v. Jonathan Q. Adams, 810 N.W.2d 365 (Iowa 2012). “Iowa Code § 814.7 (2) (2007). If we determine the record is adequate, we may resolve the claim.”
State v. Bentley, 757 N.W.2d 257 (Iowa 2008). “Iowa Code section 814.7(1) reheves defendants from the necessity of raising ineffective-assistance-of-counsel claims on direct appeal.”
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