Justia Government & Administrative Law Opinion Summaries

An inmate pled guilty to domestic abuse assault in a plea bargain that dismissed a related sex abuse charge. After the inmate arrived at a facility of the Iowa Department of Corrections (IDOC), the IDOC required the inmate to participate in a Sex Offender Treatment Program (SOTP). For the initial classification mandating SOTP, the IDOC relied on the dismissed sex abuse charge and the victim’s detailed written statement included in a police report. An administrative law judge (ALJ) upheld the determination following an evidentiary hearing based on the inmate’s admission that he assaulted his girlfriend and the victim’s statement. The district court reversed, concluding that the IDOC cannot use unproven charges to require SOTP. The Supreme Court reversed and reinstated the IDOC’s decision, holding (1) the IDOC may rely on the victim’s written statement in a police report for the initial classification requiring SOTP provided that the inmate is afforded due process; (2) the ALJ may uphold the classification based on the inmate’s testimony admitting to a sexual component to the assault along with other evidence; and (3) the inmate in this case was provided with appropriate procedural protections, and there was no other error in these proceedings. View "State v. Iowa District Court for Jones County" on Justia Law

The Dyersville City Council voted to rezone the area containing the Field of Dreams movie site from agricultural to commercial in order to facilitate the development of a baseball and softball complex. Community members filed writs of certiorari, arguing (1) since the city council acted in a quasi-judicial function, the city council’s act of passing the ordinances was invalid; and (2) there was sufficient opposition to the rezoning to trigger a unanimous vote of the city council contained in the city code. The district court annulled the writs. The Supreme Court affirmed, holding (1) the city council acted in its proper legislative function when it rezoned the subject property, and both ordinances were validly passed; and (2) no procedural or substantive errors affected the city council’s rezoning decisions. View "Residential & Agricultural Advisory Committee, LLC v. Dyersville City Council" on Justia Law

Insured filed a complaint challenging Insurer’s termination of workers’ compensation issuance. The insurance commissioner declined to consider the merits of the complaint on the ground that the complaint raised factual issues that could not be resolved by the agency. Insurer filed a petition for judicial review seeking a declaration that the insurance commissioner should have exercised jurisdiction over the dispute. The district court granted the commissioner’s motion to dismiss, concluding that Insurer lacked standing to litigate the issues. The Supreme Court dismissed Insurer’s appeal, holding that, under the circumstances presented and applying established caselaw, the appeal was moot. View "Auto-Owners Insurance Co. v. Iowa Insurance Division" on Justia Law

Appellee pled guilty to a crime listed in Iowa Code 902.12, which requires offenders to serve a mandatory minimum term of their sentence before being eligible for parole or work release. Appellee, who was a juvenile when he committed the offense, was sentenced to an indeterminate term of incarceration. The Iowa Department of Corrections (IDOC) classified Appellee’s sentence as category “B” and calculated his earned time accordingly. Appellee later filed a motion for correction of an illegal sentence based on State v. Lyle. The district court resentenced Appellee to an indeterminate term not to exceed ten years, without the mandatory minimum. The IDOC continued to calculate Appellee’s earned time at the rate provided for in category “B” rather than the faster rate provided for in category “A.” Appellee filed a motion to enlarge the sentencing order, arguing that the IDOC was not giving him full credit for his time served. The district court ruled that Appellee’s entire sentence was subject to the accelerated category “A” accumulation rate. The Supreme Court affirmed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "State v. Coleman" on Justia Law

Petitioner received a one-year driver’s license revocation and suspension for failure to submit to chemical testing. The Department of Transportation (DOT) affirmed the ALJ’s decision. Petitioner sought judicial review of the DOT’s ruling. On the thirtieth day after the DOT issued its final decision, the law firm representing Petitioner electronically submitted a petition for judicial review that was received by the Iowa Judicial Branch electronic data management system (EDMS). The next morning, the clerk’s office returned the petition because Petitioner’s address was missing from the electronic cover sheet and the filing had not been described as a “civil-administrative appeal” on that same cover sheet. The law firm resubmitted the petition after correcting the errors. Upon the motion of the DOT, however, the district court dismissed the petition as untimely because it was one day late. The Supreme Court reversed, holding that, for purposes of meeting a deadline, a filing may relate back to the original date it was received by the EDMS when the filing party demonstrates certain conditions are met. Remanded. View "Jacobs v. Iowa Department of Transportation" on Justia Law

Shannon Breeden and Laura Hochmuth, both juveniles when their crimes were committed, were convicted of forcible felonies listed in Iowa Code 902.12. Both offenders were subject to the mandatory minimum requirement to serve at least seven-tenths of their sentences before becoming eligible for parole or work release. Each offender received a sentence with a mandatory minimum, and the Iowa Department of Corrections (IDOC) classified their sentences as category “B” for purposes of calculating earned-time credit. The Supreme Court subsequently decided State v. Lyle, which required resentencing of all offenders serving prison sentences with automatically imposed mandatory minimum terms for crimes committed as juveniles. The district court then resentenced Breeden and Hochmuth to an indeterminate term of years but without a mandatory minimum. The IDOC continued to classify the offenders’ sentences as category “B” such that their earned-time continued to accrue at a slower rate than the rate provided for under category “A.” The court of appeals reversed based on the plain language of section 903A.2(1), which provides that earned-time credit accrues at the faster rate for sentences lacking a mandatory minimum term. The Supreme Court affirmed, holding that removal of the mandatory minimum triggers the faster accrual for earned-time credit. Remanded. View "Breeden v. Iowa Department of Corrections" on Justia Law

Sondra Irving was employed as a medical assistant at the University of Iowa Hospitals and Clinics (UIHC). She was arrested on November 28, 2013, and incarcerated through December 24, but the charges were ultimately dismissed. Irving was scheduled to resume work on December 3. At Irving’s request, her mother called UIHC every work day between December 2 and December 11 to report that Irving would be absent from work. On December 11, an employee at UIHC told Irving’s mother that she did not need to call anymore because Irving had been placed on a leave of absence. Irving’s supervisors at UIHC visited her on December 5 and told her they were doing everything they could to make sure she did not lose her job. Irving’s supervisors continued to visit on visiting days, and they told her that she had been placed on a leave of absence. After she was released, Irving attempted to return to work and was told that she was no longer employed. Irving attempted to reapply for her job and was rejected. Irving applied for unemployment insurance benefits on January 16, 2014, under the Iowa Employment Security Law. Iowa Workforce Development denied her application in a letter stating, “Our records indicate you voluntarily quit work on 12/20/13, because you were arrested and confined in jail. Your quitting was not caused by your employer.” Irving appealed the decision. The district court affirmed. Irving then sought certiorari review. The Supreme Court found that the EAB record did not support a finding of misconduct, and that there was no substantial support to show that Irving's absence from the workplace due to her incarceration was a voluntary quit. Accordingly, the Iowa Supreme Court reversed the EAB's decision and remanded for further proceedings. View "Irving v. Employment Appeal Board" on Justia Law

In response to a 2009 executive order announcing a ten percent reduction in state departments and agencies for the fiscal year ending June 30, 2010, the Iowa Department of Human Services (IDHS) promulgated temporary rules adjusting the reimbursement rates paid to Medicaid service providers. Thereafter, the legislature passed a law directing IDHS to continue for the next fiscal year the rate reductions as specified under the 2009 executive order. Accordingly, IDHS promulgated permanent rules implementing certain rate reductions. IDHS, however, inadvertently omitted a reduction for one component of the rate calculation for certain Medicaid service providers. Nevertheless, IDHS continued to reimburse those service providers at the reduced rates established under the temporary rules. In an administrative proceeding, Plaintiffs, several providers, challenged the rate calculation, arguing that, even if the “missing” rule was an oversight, IDHS could not reimburse them at the reduced rate without a rule authorizing it to do so. An administrative law judge granted summary judgment for IDHS, and the decision was affirmed on review. The district court reversed. The Supreme Court reversed, holding that the statute provides sufficient authority for IDHS to reimburse service providers at the reduced rates without a rule authorizing it to do so. View "Exceptional Persons, Inc. v. Iowa Dep’t of Human Servs." on Justia Law

Employee injured her back during the course of her employment. Employer paid for the cost of care Employee received to treat her injury through September 2009. Employee later brought a workers’ compensation claim seeking workers’ compensation benefits and medical expenses she incurred for additional back treatment between May 2010 and April 2011. The Workers’ Compensation Commissioner concluded that the treatment Employee received between May 2010 and April 2011 was not causally related to her workplace injury but nonetheless awarded Employee medical expenses because Employer failed to notify Employee it was no longer authorizing treatment as required by Iowa Code 85.27(4). The district court reversed in part, concluding that the agency misinterpreted section 85.27(4) and that Employer was not liable for the expenses Employee incurred after September 2009. The court of appeals reversed the portion of the district court judgment reversing the agency’s determination that Employer was liable to Employee for the expenses she incurred from May 2010 through April 2011, concluding that the district court erroneously interpreted section 85.27(4). The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the Commissioner erroneously interpreted Iowa Code 85.27(4). Remanded. View "Ramirez-Trujillo v. Quality Egg, LLC" on Justia Law

Former employees of Warren County sued the County and its Board of Supervisors, alleging a violation of the open meetings law contained in Iowa Code chapter 21. The district court dismissed the action, concluding that the board members’ activities did not constitute a “meeting” as defined in Iowa Code 21.2(2). The Supreme Court reversed, holding (1) the open meetings law prohibits a majority of a governmental body gathering in person through the use of agents or proxies to deliberate any matter within the scope of its policy-making duties outside the public view; and (2) the district court in this case incorrectly interpreted section 21.2(2) in applying the open meetings law. Remanded. View "Hutchison v. Shull" on Justia Law