Blake James Jacobs v. Iowa Department of Transportation, Motor Vehicle Division
887 N.W.2d 590
| Iowa | 2016Background
- Blake Jacobs filed a petition for judicial review of an Iowa DOT administrative decision; the 30-day statutory deadline expired on November 18, 2015.
- Jacobs’s counsel electronically submitted the petition to the Iowa EDMS on November 18 at 12:37 p.m.; the petition text was not deficient.
- On November 19 the county clerk returned the submission “Not Filed,” citing (1) a missing client address on the EDMS electronic cover sheet and (2) an incorrect case sub-type ("Civil - Other Actions" instead of "Civil - Administrative Appeal").
- Jacobs promptly corrected the cover sheet and resubmitted; the clerk then accepted and file-stamped the petition on November 19 at 9:53 a.m.
- DOT moved to dismiss as untimely; the district court granted dismissal, holding the petition was filed on November 19 and the court lacked jurisdiction.
- The Iowa Supreme Court reversed, holding a corrected resubmission may relate back to the original EDMS receipt date when (1) the original submission was received before the deadline and otherwise proper except for minor cover-sheet errors, (2) the clerk returned it after the deadline because of those minor errors, and (3) the filer promptly corrected and resubmitted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an EDMS submission returned for minor cover-sheet errors can relate back to the original EDMS receipt date to meet a statutory filing deadline | Jacobs: the original EDMS receipt (Nov 18) should control; rule 16.309(3)(c) contemplates verifying original submission date and supports relation-back | DOT: an attempted submission is not a filing; the official filing date is the EDMS notice/file-stamp (Nov 19); allowing relation-back would let filers circumvent deadlines | The Court held relation-back is allowed where (1) original submission received before deadline and otherwise proper except for minor cover-sheet errors, (2) clerk returned it after the deadline for those minor errors, and (3) filer promptly corrected and resubmitted |
Key Cases Cited
- Concerned Citizens of Southeast Polk Sch. Dist. v. City Dev. Bd., 872 N.W.2d 399 (Iowa 2015) (interpreting EDMS rules and holding the EDMS file-stamp date can be the operative filing date for court-generated documents)
- Cooksey v. Cargill Meat Sols. Corp., 831 N.W.2d 94 (Iowa 2013) (applying substantial-compliance principles to invoke jurisdiction)
- Christiansen v. Iowa Bd. of Educ. Exam’rs, 831 N.W.2d 179 (Iowa 2013) (statutory compliance is required to invoke district court appellate jurisdiction over agency actions)
- City of Des Moines v. City Dev. Bd., 633 N.W.2d 305 (Iowa 2001) (timely petition for judicial review is a jurisdictional prerequisite)
- McCormick v. Meyer, 582 N.W.2d 141 (Iowa 1998) (appellate review standard: findings binding unless unsupported by substantial evidence)
- Dwyer v. Clerk of Dist. Ct., 404 N.W.2d 167 (Iowa 1987) (clerk’s duty to file and note documents presented; clerk should not determine legal effect of documents)