Justia Government & Administrative Law Opinion Summaries

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm'n" on Justia Law

Appellants owned residential real estate in West Des Moines. In 2011, the Dallas County Board of Review established an assessment value of Appellants’ property for tax purposes. In 2012, the Board established a new, greater value for the property. Appellants filed a petition with the Board protesting the assessment. The petition stated that the protest was lodged against the 2011 property valuation. At a hearing before the Board, Appellants stated that they wished to protest the valuations for both 2011 and 2012. The Board denied Appellants’ protest, concluding that it lacked subject matter jurisdiction because the 2011 protest was untimely. The district court affirmed. The Supreme Court reversed, holding (1) Appellants’ petition was sufficient to invoke the jurisdiction of the Board and bring Appellants’ protest within the Board’s authority to review; and (2) the Board had the authority to entertain a request for amendment of Appellants’ petition and relate it back to the original filing. Remanded. View "Allen v. Dallas County Bd. of Review" on Justia Law

Arnold and Vesta Melby were trustors of separate irrevocable trusts. Both Arnold and Vesta received Medicaid benefits. After the Melbys’ deaths, the Iowa Department of Human Services notified Arnold’s estate that it would seek reimbursement for all Medicaid expenses it had paid on behalf of Arnold and Vesta. The Department then filed an application in the estate seeking a judgment declaring the Melbys had interests in the corpus of their trusts that should be counted as assets available for repayment of the Department’s Medicaid claim. The district court concluded (1) the Melbys’ interests in the trusts were limited to their right to receive the net income from the trusts’ assets, and (2) the Department’s right to recover the Medicaid payments could be enforced against such income, but not against the corpus of the trusts. The Supreme Court reversed, holding (1) the Department’s right to recover Medicaid payments under the facts of this case extended beyond the Melbys’ net income interests; and (2) the district court erred in determining the scope of medical assistance for which recovery was authorized by the general assembly. Remanded. View "In re Estate of Melby" on Justia Law

The Iowa Department of Natural Resources (DNR) revoked Plaintiffs' hunting licenses after finding that each Plaintiff did not meet the criteria to claim resident status under Iowa Code chapter 483A and that establishing residency solely for the purposes of hunting was improper under section 483A.1A(10). In each case, an administrative law judge affirmed the DNR's decision. The district court affirmed the agency action, concluding (1) to be considered a landowner for the purposes of obtaining landowner hunting privileges, a person must be a resident of Iowa, and (2) the ALJ's findings that Plaintiffs were not Iowa residents were supported by substantial evidence, notwithstanding the facts and each owned land in Iowa and paid taxes in Iowa. The Supreme Court affirmed, holding (1) the decisions of the ALJs in Plaintiffs' respective cases were supported by substantial evidence; and (2) Iowa's licensing scheme, which distinguishes between resident landowners and nonresident landowners, is not an unconstitutional impairment of privileges protected by the Privileges and Immunities Clause. View "Democko v. Iowa Dep't of Nat. Res." on Justia Law

Claimant, an undocumented worker, underwent surgery in 2007 to correct work-related hernias. Claimant returned to work, but in 2008 Employer terminated Claimant's employment. In 2007, Claimant filed for workers' compensation benefits. A deputy commissioner awarded running healing period benefits from the date of the work-related injury until Claimant reached maximum medical improvement. The Iowa Workers' Compensation Commissioner affirmed the deputy's decision. The district court affirmed, holding that substantial evidence supported the running award of healing period benefits, the Commissioner was correct in starting healing period benefits at a date prior stipulated date, and Claimant's return to work did not cut off any of her benefits. The Supreme Court affirmed in part and reversed in part, holding (1) an undocumented worker is entitled to healing period benefits under the Iowa Workers' Compensation Act; (2) the district court did not err in affirming on the issues of substantial evidence and the starting date of Claimant's benefits; and (3) Claimant was not entitled to healing period benefits while she was working. Remanded. View "Staff Mgmt. v. Jimenez" on Justia Law

Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules. View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law

A city and resident filed a petition against the Upper Explorerland Regional Planning Commission, a local governmental body, alleging various violations of the Iowa Open Meetings Act (IOMA). The district court granted summary judgment in favor of the Commission and its members (Defendants), finding (1) a volunteer of a governmental body has immunity pursuant to Iowa Code 28H.4 for damages due to alleged IOMA violations; (2) the Commission's meeting notices for its closed sessions satisfied the requirements of Iowa Code 21.4(1); and (3) the newspaper Defendants used for publication of the names and salaries of Commission members was a newspaper of general circulation under Iowa Code 28E.6(3)(a). The Supreme Court (1) affirmed as to issue of whether individual members of the Commission were immune from damages, as section 28H.4 exempts volunteers serving on councils of governments from personal liability; (2) reversed as to the reasonableness of the notice posted in the hallway of the Commission's offices, as genuine issues of material fact existed regarding whether the notice was easily accessible to the public; and (3) affirmed as to the issue of whether the publication was a newspaper of general circulation. Remanded. View "City of Postville v. Upper Explorerland Reg'l Planning Comm'n" on Justia Law

The Sierra Club and two of its local members challenged the Iowa Department of Transportation's (IDOT) decision to locate a highway adjacent to and through the Rock Island State Preserve by filing a petition for judicial review in the district court. The district court granted IDOT's motion to dismiss, finding that the Sierra Club had not exhausted all administrative remedies before filing its petition. The court of appeals dismissed the Sierra Club's appeal, finding (1) the notice of appeal was timely filed; (2) the Sierra Club was required to seek a declaratory order from IDOT before requesting court intervention; and (3) the case was not ripe for adjudication. The Supreme Court affirmed as to all issues except for ripeness, holding (1) the notice of appeal was timely because the Sierra Club triggered the tolling exception by filing a proper posttrial motion; (2) the Sierra Club must seek a declaratory order before petitioning for judicial review; and (3) the matter was ripe for adjudication. View "Sierra Club Iowa Chapter v. Iowa Dep't of Transp." on Justia Law

The Iowa Board of Nursing and Iowa Department of Public Health (collectively, Defendants) enacted rules allowing advanced registered nurse practitioners (ARNPs) to supervise radiologic technologists using fluoroscopy machines. Several physician associates brought this action against Defendants to invalidate the rules. Two nursing associations intervened to defend the rules. The district court invalidated the rules, concluding that Defendants exceeded their authority in promulgating the rules. The Supreme Court reversed, holding (1) the Board's application of law to fact was not irrational, illogical, or wholly unjustifiable; (2) the rules fell within the authority of the Board and Department; and (3) the other challenges to the rules failed. Remanded. View "Iowa Med. Soc'y v. Iowa Bd. of Nursing" on Justia Law

Petitioner was a middle school teacher involved in a physical altercation with a student. The Iowa Board of Educational Examiners issued a statement of charges against Petitioner alleging student abuse. The Board subsequently imposed a ninety-day suspension of Petitioner's teaching license and permanent revocation of his physical education and coaching endorsements. Petitioner filed a petition for judicial review in district court within thirty days of the Board's denial of his application for rehearing but before the Board's final decision on the State's application for rehearing. The district court ultimately affirmed the Board's decision on the merits. The court of appeals reversed, holding that Petitioner's "premature" petition never invoked the district court's jurisdiction. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the proper time to file a petition for judicial review is within thirty days after the agency's final decision on the last application granted for rehearing; and (2) Petitioner initially appealed prematurely before the Board's final decision on the State's rehearing application, but he later perfected his appeal to the district court. View "Christiansen v. Iowa Bd. of Educ. Examiners" on Justia Law