Iowa Code » Chapter 822 — POSTCONVICTION PROCEDURE
Iowa Code

Iowa Code § 822.8 (2026)

Grounds must be all-inclusive

✓ current as of July 2026
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All grounds for relief available to an applicant under this chapter must be raised in the applicant’s original, supplemental or amended application. Any ground finally adjudicated or not raised, or knowingly, voluntarily, and intelligently waived in the proceeding that resulted in the conviction or sentence, or in any other proceeding the applicant has taken to secure relief, may not be the basis for a subsequent application, unless the court finds a ground for relief asserted which for sufficient reason was not asserted or was inadequately raised in the original, supplemental, or amended application. [C71, 73, 75, 77, 79, 81, §663A.8] C93, §822.8

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Notes of Decisions
Cited in 172 cases (68 in the last 5 years), 1993–2026 · leading case: Brian K. Allison v. State of iowa, 914 N.W.2d 866 (Iowa 2018).
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Brian K. Allison v. State of iowa, 914 N.W.2d 866 (Iowa 2018). · cites it 51× “(emphasis omitted) (quoting Iowa Code § 822.8 (1993)). The Wilkins court contrasted this broad language with the narrow language in Iowa Code section 822.”
Ledezma v. State, 626 N.W.2d 134 (Iowa 2001). · cites it 12× “Generally, a claim not raised on direct appeal cannot be raised in a postconviction relief proceeding unless the applicant can demonstrate a sufficient cause or reason for not properly raising the issue previously.”
Dible v. State, 557 N.W.2d 881 (Iowa 1996). · cites it 28× “Iowa Code § 822.8 (emphasis added). In contrast, the exception to section 822.”
Bugley v. State, 596 N.W.2d 893 (Iowa 1999). · cites it 34× “” Iowa Code § 822.8 . Thus, the burden does not apply when the grounds were “finally adjudicated” or “knowingly, voluntarily, and intelligently waived” in a proceeding to secure relief.”
DeVoss v. State, 648 N.W.2d 56 (Iowa 2002). · cites it 8× “Iowa Code § 822.8 (1997). This provision provides an exception where “the court finds a ground for relief asserted which for sufficient reason was not asserted or was inadequately raised in the original, supplemental, or amended application.”
Manning v. State, 654 N.W.2d 555 (Iowa 2002). · cites it 10× “Iowa Code § 822.8 . An exception exists where “the court finds a ground for relief asserted which for sufficient reason was not asserted or was inadequately raised in the original, supplemental, or amended application.”
Osborn v. State, 573 N.W.2d 917 (Iowa 1998). · cites it 12× “Iowa Code section 822.8 (1997) provides that postconviction relief may not be granted on assignments not asserted in prior applications for relief in the absence of a showing of good cause.”
State v. Johnson, 784 N.W.2d 192 (Iowa 2010). · cites it 3× “§ 822.8. We have interpreted this provision to require a postconviction-relief applicant to raise any ineffective-assistance claims on direct appeal or “show sufficient reasons why any ground for relief asserted in a postconviction relief petition was not previously asserted on…”
Donnie Lee Wyldes, Jr. v. Thomas Hundley, Warden, 69 F.3d 247 (8th Cir. 1995). · cites it 7× “Additionally, the appellate court used Iowa Code § 822.8 (1995) as an alternative prohibition on reconsideration of the juror misconduct claim.”
Boss v. Ludwick, 863 F. Supp. 2d 845 (N.D. Iowa 2012). · cites it 12× “(citing Iowa Code § 822.8 ). Similarly, here, *857 Judge Zoss concluded that an attempt to exhaust Boss’s claim relating to the recording of his statements by Officer Bartolozzi would be “futile,” because any attempt to raise the claim now in state court is untimely under the…”
Arnold v. State, 540 N.W.2d 243 (Iowa 1995). · cites it 8× “We agree with the district court that such a preliminary showing on Arnold’s part was required by Iowa Code section 822.8 (1995) and was not satisfactorily made.”
Wilkins v. State, 522 N.W.2d 822 (Iowa 1994). · cites it 5× “That case interpreted section 822.8 which provides: Any ground finally adjudicated or not raised [in] the proceeding that resulted in the conviction or sentence, or in any other proceeding [to] secure relief, may not be the basis for a subsequent application, unless the court…”
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