Justia Government & Administrative Law Opinion Summaries

Employee strained his back while working for Employer. Two years later, Employer notified Employee that it would no longer pay for his medical care, believing that the two-year statute of limitations for workers’ compensation benefits had expired. Employee sought benefits from the Iowa Workers’ Compensation Commission. The deputy commissioner ruled that the two-year statute of limitations in Iowa Code 85.26 barred Employee’s claim and that, even though Employee filed a workers’ compensation proceeding within thirty days after receiving the notice from Employer, the discovery rule did not apply in this case. The district court reversed. The Supreme Court affirmed, holding that the discovery rule applied under the circumstances presented in this case. View "Baker v. Bridgestone/Firestone" on Justia Law

Petitioners petitioned for judicial review of a decision by the City Development Board approving the annexation of certain land. The district court affirmed. Petitioners filed a notice of appeal and a motion for extension of time to appeal, claiming that the annexation was improper. The Board filed a motion to dismiss the appeal as untimely filed. At issue before the Supreme Court was whether the time to file a notice of appeal in an electronically filed case begins on the day the notice of filing is electronically submitted or on the day the court order from which the appeal is taken has been electronically filed. The Supreme Court dismissed this appeal, holding (1) the notice of appeal from a final judgment or order of the district court must be filed within thirty days of the date the judgment or order was electronically filed, rather than the date of the notice of filing; and (2) the notice of appeal in this case was untimely filed. View "Concerned Citizens of Southeast Polk Sch. Dist. v. City Dev. Bd. of Iowa" on Justia Law

After an investigation, the Iowa Department of Natural Resources (DNR) determined that the release of sweet corn silage runoff from Appellant’s farming operation caused fish kill on the Winnebago River. The DNR submitted a restitution assessment to Appellant, which included a restitution amount of $61,794. After a contested hearing, an administrative law judge issued a proposed decision that affirmed the restitution assessment. The Natural Resource Commission affirmed. The district court reversed and struck the restitution assessment. On remand, the Commission reduced the restitution assessment to Appellant as a result of the fish kill to $5298. Appellant then applied for an award of attorney fees pursuant to Iowa Code 625.29. The district court denied the motion, finding that three exceptions to the requirement to award attorney fees applied. The court of appeals reversed, concluding that none of the exceptions found in section 625.29(1) applied to Appellant’s case to preclude an award of attorney fees and that the district court should have found Appellant was the prevailing party under the statute. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the State’s role in this case was primarily adjudicative, precluding an award of attorney fees. View "Brandstad v. State ex rel. Nat. Res. Comm’n" on Justia Law

Susan Heathcote and Carrie La Seur served on the Environmental Protection Commission during a period of time when the Commission considered the adoption of rules to prevent the degradation of Iowa’s water resources. In 2009, the Commission voted to approve two antidegradation rules and procedures, which were approved by the EPA. Plaintiffs sought to overturn the rule and regulation, alleging that Heathcote was disqualified to vote because she engaged in activities in her employment in support of the rule and that La Seur was disqualified to serve on the Commission at the time she voted because she had moved to Montana and lost her status as an elector in Iowa. The district court granted summary judgment to the Commission regarding both Heathcote’s and La Seur’s participation. The Supreme Court affirmed, holding (1) the nature of rulemaking does not disqualify a Commission member from voting to adopt rules she personally and professionally supported; and (2) the disqualification of a Commission member did not invalidate the action taken by the Commission when the disqualification did not undermine the integrity of the process and the public interest supported validating the rule despite the disqualification. View "Iowa Farm Bureau Fed'n v. Envtl. Prot. Comm'n" on Justia Law

Plaintiff was injured when she crashed on her bicycle while riding on a sidewalk abutting the grounds of the University of Iowa in Iowa City. Plaintiff filed a negligence action against the City, claiming that an alleged defect in the sidewalk caused the accident. The City filed a motion to add the State as a third-party defendant, citing the City’s ordinance requiring an abutting property owner to maintain the sidewalk in a safe condition. The district court granted the motion. The City then filed a cross-claim against the State seeking contribution. The district denied the State’s motion to dismiss the City’s cross-claim, concluding (1) the City’s contribution claim was not excluded from the Iowa Tort Claims Act (ITCA) and adequately pled a claim under the ITCA; and (2) an ordinance can establish a duty, the breach of which supports a negligence claim. The Supreme Court affirmed, holding (1) the City’s ordinance was not preempted by Iowa Code 364.12(2); (2) the potential imposition of indemnity under the ordinance does not give rise to an unlawful tax; and (3) the City’s claim against the State was within the scope of ITCA for purposes of waiver of sovereign immunity. View "Madden v. City of Iowa City" on Justia Law

The Iowa Utilities Board (IUB) allowed an independent transmission company, ITC Midwest, to use the pay-and-go procedure of Iowa Code 476.27, the railroad-crossing statute, to run electrical power lines across a railroad at three locations, at the objection of the Hawkeye Land Company. Hawkeye Land owned the railroad-crossing easement but did not own or operate a railroad. An administrative law judge (ALJ) upheld the use of the pay-and-go procedure and denied compensation beyond the $750 standard per crossing fee the utility pays to the owner of the railroad right-of-way under the crossing statute. After concluding that it had interpretive authority over the crossing statute, the IUB issued a final order that reached the same conclusions as the ALJ. The district court affirmed on judicial review. The Supreme Court reversed, holding (1) the IUB lacked interpretive authority over the terms of the crossing statute; and (2) the crossing statute applied to Hawkeye Land, but because ITC Midwest was not a public utility, it was not allowed to use the pay-and-go procedure. View "Hawkeye Land Co. v. Iowa Utils. Bd." on Justia Law

After Appellant drove her car off the road and destroyed a mailbox, Appellant gave a urine sample that tested positive for controlled substances. Based on the test results, the Iowa Department of Transportation revoked Appellant’s license for 180 days. Appellant contested her revocation, asserting that the prescription-drug defense under Iowa Code 321J.2(11) applied in her case. An administrative law judge denied the appeal, finding that the evidence in this case established the elements of the statutory prescription-drug defense but that the prescription-drug defense did not apply in administrative license revocation proceedings. The district court affirmed. The Supreme Court reversed, holding that the prescription-drug defense is available in license revocation proceedings. View "Bearinger v. Iowa Dep't of Transp." on Justia Law

In 2005, James House began working as a commercial truck driver for Mike Brooks, Inc. In 2007, House slipped and fell in any icy parking lot while retrieving cargo and injured his back. House returned to work but experienced regular back pain after doing so. In 2008, House pushed open a heavy door and experienced an increase in pain and a burning sensation in the area of his 2007 back injury. House filed a petition for workers’ compensation benefits. A deputy commissioner found House had sustained a permanent total disability (PTD) and rejected Brooks’ contention that the 2008 incident resulted in an injury distinct from the 2007 injury. The commissioner affirmed the award of PTD benefits, including the finding that House’s injury and resulting PTD were caused by the 2007 incident. The district court affirmed. The court of appeals reversed, concluding that the commissioner’s finding of causation was not supported by substantial evidence. The Supreme Court vacated the court of appeals and affirmed the district court’s decision, holding that substantial evidence supported the causation finding made by the commissioner. View "Mike Brooks, Inc. v. House" on Justia Law

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