Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Election Law
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The Supreme Court affirmed the judgment of the trial court denying relief in this declaratory judgment action to force a public referendum on the financing of a school district's proposed athletic stadium, holding that Plaintiffs failed to show prejudice to obtain judicial relief for a technical violation in their petition.Plaintiff-citizens collected signatures to force the public referendum at issue, but the school board determined that the number of signatures were insufficient to force a referendum. The school district, therefore, declined to accept the petition or proceed with the referendum. Plaintiff then brought this declaratory judgment action to force the referendum. The trial court granted summary judgment denying relief. The Supreme Court affirmed, holding (1) Plaintiffs' petition was facially invalid as lacking the requisite number of signatures; (2) the district court breached a directory duty under Iowa Code 277.7 to return the rejected petition, but Plaintiffs failed to show prejudice; and (3) therefore, Plaintiffs' due process claims failed, and summary judgment was proper. View "Save Our Stadiums v. Des Moines Independent Community School District" on Justia Law

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In this case involving Democrat Abby Finkenauer's candidacy for U.S. Senate the Supreme Court sustained the State Objections Panel's decision to reject objections as to the signatures of three electors who had provided either no date or a clearly incorrect date, holding that there was no error.If the objectors' position as to the signatures in this case had been sustained, Finkenauer would have failed to meet the requirements to be placed on the June 7, 2022 Democratic primary ballot. The Panel allowed Finkenauer's nomination petition. The district court reversed, holding that the three undated or improperly dated signatures should not have been counted. At issue was Iowa Code 43.15(2), which makes the date a legal requirement when an eligible elector signs a nomination petition, and recent legislation passed last year, Iowa Code 43.24(2)(a), which did not include missing or incorrect dates as one of the grounds for sustaining an objection to a petition. The Supreme Court reversed, holding that the recent legislation prevailed. View "Schmett v. State Objections Panel" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the decision of the district court denying Plaintiffs' temporary injunction request seeking to invalidate the legislature's statute providing additional election safeguards, holding that the statute does not impose a significant burden on absentee voters.The state election law at issue requires that county auditors contact an applicant when they receive a defective absentee ballot request that omits or contains incorrect statutorily required identification information in order to obtain the required identification information. Plaintiffs argued that such a requirement, as opposed to county auditors attempting to correct the defective requests without additional contact with the applicant, imposes a severe burden on the right to vote. The Supreme Court declined to set aside the state law for purposes of the November 3, 2020 election, holding that the district court did not err in denying Plaintiffs' temporary injunction request. View "League of United Latin American Citizens Of Iowa v. Pate" on Justia Law

Posted in: Election Law
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The Supreme Court vacated the orders of the district court staying an emergency election directive issued by the Secretary of State concerning the 2020 general election, holding that the district court abused its discretion in issuing the stay.The directive stated that the Secretary will mail a blank absentee ballot request form with instructions to every Iowa voter for the November 3, 2020 general election. At issue was the second paragraph in the directive stating, "To ensure uniformity and to provide voters with consistent guidance on the absentee ballot application process, County Auditors shall distribute only the blank Official State of Iowa Absentee Ballot Request Form..." When county auditors in three counties began mailing absentee ballot applications to registered voters that were refilled with individual voter information, various Republican campaign organizations filed petitions for injunctive relief. The district courts enjoined the county auditors from accepting prepopulated forms. Several Democratic campaign organizations filed an emergency motion to stay in Polk County seeking to block enforcement of the second paragraph of the directive. The district court granted a statewide stay of enforcement of the Secretary's order. The Supreme Court vacated the stay, holding that Iowa Code 53.2 authorized the Secretary's directive and that other grounds did not support the district court's ruling. View "Iowa Secretary of State v. Democratic Senatorial Campaign Committee" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing for lack of standing Attorney's petition for judicial review of the decision of the Iowa Ethics and Campaign Disclosure Board dismissing Attorney's complaint that the Governor had underreported the fair market value of a trip to Tennessee, holding that the district court properly concluded that Attorney lacked standing in this case.To comply with campaign disclosure requirements, the Governor's campaign committee reported the trip as a $2800 campaign contribution from an individual donor. Attorney complained to the Board that the Governor had underreported the fair market value of the trip, but the Board dismissed the complaint. Attorney petitioned for judicial review. The district court dismissed the petition, concluding that Attorney had not been injured by the Board's action, nor had he been deprived of any information. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Attorney was not an "aggrieved or adversely affected" party within the meaning of Iowa Code 17A.19; and (2) because Attorney did not allege he was lacking any relevant information but merely voiced a a disagreement over the reporting method used by the candidate committee, Attorney lacked standing. View "Dickey v. Iowa Ethics & Campaign Disclosure Board" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court entering an injunction directing Defendants to place on the ballot a measure asking voters whether they approved the demolition of Hoover Elementary School and the use of the proceeds for school district purposes, holding that the district court erred in granting Plaintiffs injunctive relief.The Iowa City Community School District refused to authorize the placement of the ballot issue at an election after a petition bearing more than 2000 signatures had been timely filed with the Board. When the Board refused to direct the county auditor to place the matter on the ballot for the upcoming election, Plaintiffs sought injunctive relief and damages against the school district court individual board members. The district court entered an injunction and directed the district court to place the matter on the next general election ballot. The district court then granted Defendants summary judgment on Plaintiffs' claims for damages. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all claims because the school district was under no legal obligation to require the county auditor to place the matter on the ballot. View "Young v. Iowa City Community School District" on Justia Law

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Kelli Jo Griffin was convicted for the crime of delivery of a controlled substance. Griffin later registered to vote and cast a provision ballot in a municipal election. The county auditor concluded that Griffin was not eligible to vote due to her felony conviction and rejected her ballot. Griffin filed a petition asking the district court to declare that her felony conviction did not disqualify her from voting under the Iowa Constitution. The district court denied relief. At issue on appeal was whether the felony crime of delivery of a controlled substance is an “infamous crime” under the voter disqualification provision of the Iowa Constitution. The Supreme Court affirmed, holding that the Constitution permits persons convicted of a felony to be disqualified from voting in Iowa until pardoned or otherwise restored to the rights of citizenship. View "Griffin v. Pate" on Justia Law

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On March 11, 2014, Anthony Bisignano filed an affidavit of candidacy for Iowa Senate in District 17 with the Iowa Secretary of State. Ned Chiodo filed an objection to the affidavit of candidacy, claiming that Bisignano was disqualified from holding public office based on his prior conviction of the crime of operating while intoxicated (OWI), second offense. A three-person state elections panel denied the objection, and the district court affirmed. The Supreme Court affirmed, holding that a person convicted of the crime of OWI, second offense, is not disqualified from holding a public office in Iowa. View "Chiodo v. Section 43.24 Panel" on Justia Law

Posted in: Election Law
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The Iowa Right to Life Committee (IRTL) filed a complaint in the U.S. district court, alleging, inter alia, that Iowa's campaign finance laws unconstitutionally imposed political committee status on corporations whose major purpose was something other than nominating or electing candidates. The district court certified two questions to the Supreme Court. At issue before the Court was whether a corporation must form a political committee under Iowa law if it wants to spend more than $750 advocating the election or defeat of Iowa candidates. The Court answered that a corporation like IRTL may engage in express advocacy without forming a political committee because a corporation making independent expenditures aggregating over $750 in a calendar year becomes an "independent expenditure committee" within the meaning of Iowa Code 68A.404 but not a "political committee" within the meaning of Iowa Code 68A.102(18) or a "permanent organization" within the meaning of Iowa Code 68A.402(9). View "Iowa Right to Life Comm., Inc. v. Tooker" on Justia Law