Justia Government & Administrative Law Opinion Summaries

Employee sought unemployment benefits from Iowa Workforce Development after his discharge from employment by Employer. An ALJ concluded Employee was not entitled to benefits, and the Employment Appeal Board (EAB) affirmed. Employee petitioned for judicial review, naming Employer in the caption as a "defendant." The caption made no mention of the EAB, but the body of the petition made it plain that the appeal was being taken from the final action of the EAB. The petition was timely served on the EAB. The district court dismissed the petition, concluding that Employee's failure to list the EAB as a respondent in the caption was fatal. The Supreme Court reversed and remanded, holding that the district court erred in dismissing the petition where Employee substantially complied with the relevant statute by identifying the EAB as the agency who entered the final agency action from which Employee sought to appeal. Thus, the petition was sufficient to vest subject matter jurisdiction with the district court. View "Cooksey v. Cargill Meat Solutions Corp." on Justia Law

Chartis Insurance issued two workers' compensation insurance policies to Action Warehouse Company. Action, in turn, contracted with two tire companies to provide employees to operate tire warehouses owned by the companies and used exclusively to store the goods manufactured by the respective employers. Originally, Chartis classified the Action employees who staffed the warehouses under the National Council on Compensation Insurance (NCCI) classification code applicable to general warehouse employees. Later, Chartis retroactively and prospectively changed the employees' classification code to the code applicable to rubber tire manufacturing, resulting in a significantly higher premium. Action appealed. The NCCI Iowa workers' compensation appeals board ruled in favor of Chartis. The Iowa Insurance Commissioner reversed, and the district court affirmed. At issue before the Supreme Court was whether the Commissioner had the authority under Iowa Code 515A.1 to consider an as-applied challenge to a workers' compensation liability insurance rating schedule approved for use in accordance with Iowa law. The Supreme Court reversed, holding that the Commissioner did not have the authority to determine that a specific application of a plan approved under Iowa Code 515A.4 violated the statute's general purpose as outlined in section 515A.1 by being excessive, inadequate, or unfairly discriminatory. View "Chartis Ins. v. Iowa Ins. Comm'r" on Justia Law

Employee was injured while working for Employer and was awarded permanent partial disability benefits. Employee subsequently petitioned to review-reopen his workers' compensation claim, seeking additional workers' compensation benefits, seeking reimbursement for additional postarbitration medical expenses, requesting a determination of the amount of workers' compensation benefits still owed by Employer and its insurer, and asking the court to decide whether the workers' compensation commissioner needed to enter an additional order compelling payment to enforce an arbitration award for the unpaid benefits. The district court (1) rejected Employee's petition for review as untimely; (2) affirmed denial of reimbursement for some of Employee's medical expenses; and (3) did not provide the requested calculation but ruled that a compel-payment order was unnecessary because Employee could seek a judgment to enforce the award. The Supreme Court (1) reversed as to the statute of limitations for a petition for review-reopening; and (2) affirmed as to the judgment regarding which medical expenses were causally connected to the work-related injury. Remanded to the district court for it to remand the matter to the commissioner with directions to decide the issues regarding the amount still owed to Employee by Employer and its insurer under the arbitration award. View "Coffey v. Mid Seven Transp. Co." on Justia Law

Employee, who was injured while working for Employer, sought enforcement of an arbitration award he received from the workers' compensation commissioner against Employer and Employer's insurer. Employee requested the district court to determine the amount Employer and its insurer (collectively, Appellees) owed him under the arbitration award in light of Employee's claim that Appellees failed to pay all of the medical benefits, mileage reimbursements, and interest due under the arbitration decision. Appellees claimed a credit against any amount they owed Employee due to his third-party settlements. After a hearing, the district court declined to answer the issues raised by the parties and declined to determine the amount still owed to Employee under the arbitration decision, concluding that addressing the issues in Employee's petition required the district court to exceed its authority. The Supreme Court reversed and remanded to the district court for the court to remand the matter to the commissioner with directions to decide the issues Employee raised in his petition for judgment. View "Coffey v. Mid Seven Transp. Co." on Justia Law

Attorney represented MC Holdings, LLC, a landowner in Davis County, and Keo Rental, LLC, a landowner in Van Buren County, both of whom desired to protest the property-tax assessment made by their county assessors. Attorney sent the protests to the respective county boards of review on the deadline for such filings but inadvertently switched the two petitions. Consequently, the Davis County Board of Review received the Van Buren County petition with the Davis County cover letter, and vice versa. The Davis County and Van Buren County boards of review denied the protests as improperly filed, finding Attorney's clients did not file a timely protest. The boards of review denied Attorney's applications for reconsideration. The district court denied summary judgment requested by the boards, finding the cover letters constituted substantial compliance with the statutory requirements for a protest. The Supreme Court affirmed, holding that the Davis County Board had jurisdiction to consider the motion for reconsideration. Remanded. View "MC Holdings, LLC v. Davis County Bd. of Review" on Justia Law

The Iowa Department of Transportation (IDOT) suspended a commercial driver's license (CDL) for one year for operation of a commercial motor vehicle with an alcohol concentration of .04 or more. The driver contested the suspension on the ground that the IDOT had erred in concluding that in the CDL context, breathalyzer test results are not to be adjusted for the breathalyzer test's recognized margin of error. The district court and court of appeals affirmed the IDOT decision. The Supreme Court affirmed, holding that there was no indication in the structure or language of the relevant statutes that the legislature intended that a breathalyzer test result be adjusted by the recognized margin of error in making an alcohol concentration determination for the purpose of CDL suspensions. View "Watson v. Iowa Dep't of Transp." on Justia Law

In 2006, the Iowa Department of Revenue assessed the value of Qwest Corporation's Iowa operating property. Qwest protested the assessment by challenging the general assembly's previous decision to tax the personal property of incumbent local exchange carriers (ILECs) but not competitive long distance telephone companies (CLDTCs) or wireless providers operating in Iowa. Specifically, Qwest argued that the tax scheme which taxed ILECs for the value of their personal property but not CLDTCs and wireless providers violated Qwest's equal protection rights. The State Board of Tax Review (Board) concluded that Qwest's constitutional rights were not violated. The district court reversed. The Supreme Court reversed the district court and upheld the Board's assessment on Qwest, holding that imposing a tax on Iowa-based personal property of ILECs but not on that of CLDTCs or wireless service providers did not violate the Iowa Constitution, as the differential tax treatment of these enterprises is rationally related to legitimate state interests in encouraging the development of new competitive telecommunications infrastructure while raising revenue from those providers that historically had a regulated monopoly and continue to enjoy some advantages of that monopoly. View "Qwest Corp. v. State Bd. of Tax Review" on Justia Law

In this case the Supreme Court was asked to determine whether Iowa's workers' compensation statute allows a claimant to recover healing period benefits - after he had reached maximum medical improvement and returned to substantially similar work following a work-related injury - for a period of approximately thirteen weeks of postsurgical convalescence during which he was unable to work. The workers' compensation commission awarded such benefits, and the district court affirmed. The court of appeals reversed on the ground that Iowa Code 85.34(1) did not authorize the benefits under the circumstances of this case. The Supreme Court vacated in part the decision of the court of appeals and affirmed the district court's judgment affirming the award, holding that section 85.34(1) did authorize an award of healing period benefits in this case.

Chicago Central and Pacific Railroad Company (CCP) voluntarily performed repairs on a drainage improvement. When its request for reimbursement for those repairs was denied by the Calhoun County Board of Supervisors, the party responsible for keeping drainage district improvements in repair, CCP filed a petition for an appeal. The district court dismissed CCP's petition and entered judgment in favor of the Board, concluding that the CCP was liable for the costs of repair. The court of appeals affirmed. the Supreme Court vacated the court of appeals and affirmed the district court, albeit on a different basis, holding (1) under the statutory scheme enacted by the legislature, the Board has the duty to keep improvements in repair, but it also has the discretion to decide how to fulfill that duty; and (2) because CCP's suit essentially asked the Court to remove the Board's discretion while leaving its responsibilities intact, the suit was not permitted by law, and the district court properly dismissed the action.

NextEra Energy Resources, LLC appealed the Iowa Utility Board's decision to grant advance ratemaking principles to MidAmerican Energy Company for a proposed wind generation facility. The district court affirmed the Board. The Supreme Court affirmed, holding (1) the Board properly interpreted and applied Iowa Code 476.53; (2) substantial evidence supported the Board's findings; (3) Iowa Code 476.43 was not applicable to this ratemaking proceeding; and (4) section 476.53 as applied to a rate-regulated public utility that may compete in the wholesale energy market did not violate the Equal Protection clauses of the Iowa or U.S. Constitutions or the Commerce Clause of the U.S. Constitution.