Statutory wins, constitutional silence

Iowa reverses on the predicate. It does not reverse on the ex parte machine.

No Iowa court has held § 236.4 ex parte orders, the preponderance standard, or § 664A.3 mandatory orders unconstitutional. The winning theory has been statutory: an assault for chapter 236, a conviction for a five-year criminal order, and a continuing threat to extend one.

The seven sections at issue

Section	What it does	Safeguard gap
§ 236.4	Civil temporary order on a "present danger" showing; hearing set 5 to 15 days out.	Safeguard I rests on a one-sided assertion. The hearing date meets safeguard II.
§ 236.5(2)	Duration and extension of the civil order after hearing.	The bill would tie any extension to written findings of continued necessity.
§ 236.6	After-hours emergency order; dies in 72 hours. HF 523 (2026), effective July 1, 2026, widened access.	Meets safeguard II — the short fixed life the criminal order lacks.
§ 664A.3	The magistrate shall enter a criminal no-contact order at initial appearance on probable cause plus a safety finding. The protected person cannot drop it.	No hearing on the order itself; no fixed end. Life of the case.
§ 664A.5	After a qualifying conviction, plea, or deferred judgment, a no-contact order up to five years.	No findings requirement. State v. Hall (Iowa May 22, 2026, unanimous): the conviction is the only condition precedent, and the court "is not required to consider additional proof, make additional findings, or offer additional explanations." Only the Legislature can add one.
§ 664A.6	Arrest is mandatory when an officer has probable cause of a violation.	Certain cost. The contact that triggers it can be thin — see Labinski.
§ 664A.7	Violation is contempt; for a listed offense the minimum is seven consecutive days in jail — no deferral, suspension, or fine in its place.	Certain cost. Willfulness is the only gate, and it is fought at the hearing, not on appeal.

Where respondents win

Runyan, Owens, Ewoldt, G.B., Budweg: fear, reaching for a child at an exchange, or a message without immediacy and apparent ability is not an assault. The order goes away.
Wiederien (2006, 4–3): no extension after acquittal under § 708.12(2), the predecessor of chapter 664A. The Iowa Supreme Court's due-process doubt about the no-contact statute.
Rasmussen (7 N.W.3d 357, 2024): an order in a dismissed case is a void illegal sentence. Five years requires a conviction.
Vance, Petro, J. Doe: extensions reversed when the continuing-threat record fails. The burden stays on the defendant.
Ary and Conrad: contempt requires willfulness beyond a reasonable doubt, and a competing pair of orders can defeat it at trial.

Where the machine holds

Howsare (2023): a misdemeanor arrestee can be held until initial appearance so the magistrate can consider the order.
Hall (May 22, 2026, unanimous): a five-year order needs no findings, proof, or explanation beyond the conviction; notice plus the sentencing hearing is the process due. Adopts Hunter (Ct. App. 2026) and Lynch (Ct. App. 2021); Toler Sr. (Ct. App. 2026) is the same rule applied to an infant son.
O'Brien v. Young and Flores v. Aragon Nunez (December 17, 2025): expired-order appeals dismissed as moot, no presumption of collateral consequences for chapter 236 orders, following McGuire (2024), Henson (2022), and R.M. v. D.S. (2023). T.F. v. C.G. (February 2025) is the exception, decided "in an abundance of caution."
Goldston and King: credibility and a final home-and-firearm order affirmed.
Ness (Minnesota) and Crespo (New Jersey) are the foreign cases an Iowa court will be handed if someone argues the scheme is unconstitutional on its face.

Three outliers

Case	What Iowa did	The contrary line
Henley (1995, P)	The protected party can be held in contempt (seven days, suspended) for aiding a violation of her own order, following Hutcheson (1992).	Ohio Lucas, Washington Dejarlais, Kansas Branson, Indiana Patterson: the order regulates the respondent.
O'Brien v. Young (Dec. 2025, P)	Expiry moots the appeal. Relationship harm is conjecture. Ask for expedited briefing or lose the point.	T.F. v. C.G., the one Iowa exception; Putman (Connecticut), Hawaii, Maine, Massachusetts. Ohio Cyran is the adverse high-court twin, and its dissent is the brief.
Hall (May 2026, P)	Five years, no findings, once there is a qualifying conviction. Unanimous; only the Legislature can change it.	Wiederien on standardless extensions. Ness is the adverse authority that notice plus a hearing can be enough even when the hearing looks pro forma.

Checks that are missing, in one list

No candor duty on the ex parte petition, and no discharge-and-fees rule when the petition omits a material fact.
No bond. Doehr treated the missing bond as part of the due-process violation for a home attachment. Chapter 236 has no respondent bond.
No hearing on the criminal order itself. Bond review under § 811.2 is not Crawford and it is not Fernando A.
No fixed end for the pretrial criminal order. The civil emergency order dies in 72 hours. The criminal order waits for the case.
No required reasons for the five-year order. Hall settled it.
No respondent fee shift when the petition fails. Runyan denied them.
No mootness rule that keeps the appeal alive. O'Brien and Flores state the rule, and only a record of legal consequences plus expedited submission gets around it.
No published measurement of repeat harm, accidental-contact contempt, or reversal rates.

The assault predicate is the check that works. It works on appeal, after the temporary order has already done its work, and only when the papers lack immediacy and apparent ability. That is a back-end check. The four safeguards are front-end checks. Iowa has the back end on chapter 236 and is thin on both ends of chapter 664A.

Authorities, with P / S / U The long memo