Iowa Code

Iowa Code § 822.3A (2026)

Pro se filings by applicants currently represented by counsel

✓ current as of July 2026

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1. Except as otherwise provided in subsection 3, an applicant seeking relief under section 822.2 who is currently represented by counsel shall not file any pro se document, including an application, 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 an applicant for postconviction relief from proceeding without the assistance of counsel.

3. A represented applicant for postconviction relief may file the following pro se documents:

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

b. A pro se notice of appeal. 2019 Acts, ch 140, §35; 2022 Acts, ch 1110, §2 See also §814.6A \n

Notes of Decisions

Cited in 21 cases (21 in the last 5 years), 2021–2023 · leading case: John Lee Hrbek v. State of Iowa (Iowa 2021).

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John Lee Hrbek v. State of Iowa (Iowa 2021). · cites it 32× “Hrbek raises several arguments contesting the applicability and constitutionality of section 822.3A. Hrbek contends the new law is inapplicable here because the new law should not be applied retrospectively to postconviction-relief proceedings pending on the effective date of…”

Larry Dean Boring v. State of Iowa (Iowa Ct. App. 2021). · cites it 20× “The State asserts Boring may not avail himself of the exception because section 822.3A prohibits pro se filings such as his rule 1.”

Arzel Jones v. State of Iowa (Iowa 2022). · cites it 16× “For the reasons explained below, we hold that Jones’s pro se notice of appeal filed in 2021 while he was represented by counsel was a nullity under Iowa Code section 822.3A (2021), which prohibits the filing of pro se documents by represented parties and the court’s…”

Wendell Harrington v. State of Iowa (Iowa Ct. App. 2022). · cites it 12× “His claims include (1) a constitutional challenge to his statutory inability to submit pro se appellate briefs following the 2019 enactment of Iowa Code section 822.3A; (2) that he should have been granted a new trial following the discovery of new evidence regarding drug use by…”

Chester Howard Greenup v. State of Iowa (Iowa Ct. App. 2021). · cites it 7× “In 4 a single-justice order, relying on Iowa Code section 822.3A(1) (Supp. 2019),2 which directs applicants currently represented by counsel to not file any pro se document in any Iowa court and prevents courts from considering the same, the supreme court took no action on…”

Tajh Malik Ross v. State of Iowa (Iowa Ct. App. 2021). · cites it 6× “2d 779 , 782–89 (Iowa 2021) (rejecting various challenges to section 822.3A and directing the clerk of the supreme court “to strike [the applicant]’s pro se supplemental briefs”); Haywood v.”

Imere De'Jon Hall v. State of Iowa (Iowa Ct. App. 2022). · cites it 6× “1 1 Hall also asserts a constitutional challenge to Iowa Code section 822.3A (supp. 2019), which prohibits pro se filings by PCR applicants who are represented by counsel.”

Philip Stacy v. State of Iowa (Iowa Ct. App. 2021). · cites it 4× “The court also noted it would not consider any additional pro se filings due to Iowa Code section 822.3A (Supp. 2019)—which prohibits filing and consideration of pro se filings when an applicant is represented by counsel— recently taking effect.”

State of Iowa v. Dieudonne Manirabaruta (Iowa Ct. App. 2021). · cites it 4× “Our supreme court recently rejected this claim in relation to the statute’s postconviction-relief counterpart, section 822.3A. Hrbek v. State, 958 N.W.2d 779 , 783 (Iowa 2021) (“[T]he application of section 822.”

John Arthur Wilson v. State of Iowa (Iowa Ct. App. 2021). · cites it 4× “The court also entered an order concerning a pending pro se motion to enlarge and amend, explaining that per Iowa Code section 822.3A (2020),2 it would take no action on the self- represented filing.”

State of Iowa v. George Davis (Iowa 2022). · cites it 4× “State, we confronted a similar statute, Iowa Code section 822.3A, barring certain pro se documents in postconviction-relief proceedings.”

Show all 21 citing cases →

— Iowa Code § 822.3A(1) — 7 cases

Larry Dean Boring v. State of Iowa (Iowa Ct. App. 2021). “The State asserts Boring may not avail himself of the exception because section 822.3A prohibits pro se filings such as his rule 1.”

Tajh Malik Ross v. State of Iowa (Iowa Ct. App. 2021). “2d 779 , 782–89 (Iowa 2021) (rejecting various challenges to section 822.3A and directing the clerk of the supreme court “to strike [the applicant]’s pro se supplemental briefs”); Haywood v.”

Chester Howard Greenup v. State of Iowa (Iowa Ct. App. 2021). “In 4 a single-justice order, relying on Iowa Code section 822.3A(1) (Supp. 2019),2 which directs applicants currently represented by counsel to not file any pro se document in any Iowa court and prevents courts from considering the same, the supreme court took no action on…”

Jack Lewis Good v. State of Iowa (Iowa Ct. App. 2021).

Philip Stacy v. State of Iowa (Iowa Ct. App. 2021). “The court also noted it would not consider any additional pro se filings due to Iowa Code section 822.3A (Supp. 2019)—which prohibits filing and consideration of pro se filings when an applicant is represented by counsel— recently taking effect.”

— Iowa Code § 822.3A(2) — 1 case

In the Matter of V.H., Alleged to be Seriously Mentally Impaired, V.H. (Iowa 2023).

— Iowa Code § 822.3A(3) — 2 cases

Larry Dean Boring v. State of Iowa (Iowa Ct. App. 2021). “The State asserts Boring may not avail himself of the exception because section 822.3A prohibits pro se filings such as his rule 1.”

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