Berryhill v. State

In Berryhill v. State, 603 N.W.2d 243 (Iowa 1999), the Iowa Supreme Court considered and rejected a postconviction relief applicant's contention that the trial record was insufficient to pursue a direct appeal. Berryhill v. State, 603 N.W. 2d 243 (Iowa 1999). The court stated, "our frequent preference to preserve ineffective assistance claims for postconviction relief does not alleviate the need to at least raise the claim on appeal." Id. at 245-46. The court noted "a rule which requires all claims to be raised on direct appeal is not necessarily inexpedient." Id. at 246. However, the court stopped short of holding that an insufficient trial record will never be deemed grounds for bypassing a direct appeal. Id. at 245. The court explained "factual or legal matters which were excusably unknown at the time of the trial and appeal may be properly asserted on postconviction relief." Id.