Full Opinion

IN THE COURT OF APPEALS OF IOWA _______________ No. 25-1898 Filed November 4, 2026 _______________ Bank of America, N.A., Plaintiff–Appellee, v. Clinton Cherrian Jose, Defendant–Appellant. _______________ Appeal from the Iowa District Court for Polk County, The Honorable Lawrence P. McLellan, Judge. _______________ AFFIRMED _______________ Clinton C. Jose, West Des Moines, self-represented appellant. Adolfo Brandon Sanchez of Gurstel Law Firm, P.C., Golden Valley, Minnesota, attorney for appellee. _______________ Considered without oral argument by Tabor, C.J., and Greer and Ahlers, JJ. Opinion by Ahlers, J. 1 AHLERS, Judge. Clinton Jose appeals from an adverse summary judgment ruling. However, his appellate brief is deficient in several material ways. First, it does not contain a statement of facts as required by Iowa Rule of Appellate Procedure 6.903(2)(a)(6). Second, there is no error-preservation statement in the argument section. Iowa R. App. P. 6.903(2)(a)(8)(1). Third, and most critically, there are no citations to authority or relevant parts of the record in the argument section. Iowa R. App. P. 6.903(2)(a)(8)(3). “Failure to cite authority in support of an issue may be deemed waiver of that issue.” Id. We recognize that Jose is self-represented and may not be familiar with our appellate rules. But “[w]e do not utilize a deferential standard when persons choose to represent themselves.” Metro. Jacobson Dev. Venture v. Bd. of Rev. of Des Moines, 476 N.W.2d 726, 729 (Iowa Ct. App. 1991). “The law does not judge by two standards, one for lawyers and the other for lay persons. Rather, all are expected to act with equal competence. If lay persons choose to proceed pro se, they do so at their own risk.” Id. We are prohibited from “assum[ing] a partisan role and undertak[ing] a party’s research and advocacy when a party’s failure to follow the rules would require us to do so to reach the merits of the case.” State v. Lange, 831 N.W.2d 844, 847 (Iowa Ct. App. 2013). Given the lack of supporting authority contained in Jose’s appellate brief, we would have to undertake the partisan role of seeking out any supporting authority to meaningfully address and develop his appellate arguments. We decline to do so. See Inghram v. Dairyland Mut. Ins. Co., 215 N.W.2d 239, 240 (Iowa 1974). As a result, we summarily affirm. See In re Maryann Bennett Tr., No. 23-0895, 2024 WL 3688871, at *1 (Iowa Ct. App. Aug. 7, 2024). AFFIRMED. 2