HRBEK v. STATE

No. 19-1571.

958 N.W.2d 779 (2021)

John Lee HRBEK, Appellant, v. STATE of Iowa, Appellee.

Supreme Court of Iowa.

Filed April 16, 2021.

Rehearing Denied May 19, 2021.


Attorney(s) appearing for the Case

Philip B. Mears of Mears Law Office, Iowa City, for appellant.

Thomas J. Miller , Attorney General, Louis S. Sloven , Assistant Attorney General, Matthew D. Wilber , County Attorney, and Patrick A. Sondag , Assistant County Attorney, for appellee.

McDonald, J., delivered the opinion of the court, in which Waterman, Mansfield, and Oxley, JJ., joined. McDermott, J., filed an opinion concurring in part and dissenting in part, in which Christensen, C.J., and Appel, J., joined.


In the spring of 2019, the legislature passed and the governor signed an omnibus crime bill. See 2019 Iowa Acts ch. 140. As relevant here, effective July 1, 2019, the new law prohibits postconviction-relief applicants represented by counsel from filing "any pro se document, including an application, brief, reply brief,...

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