Brian Sydnes v. Iowa Department of Human Services
15-1862
| Iowa Ct. App. | Nov 9, 2016Background
- J.S., a teenage daughter, attempted suicide after ongoing parental conflict; hospital psychiatrist Dr. Eric Boyum reported mental injury and DHS opened an assessment.
- DHS initially deemed the allegations unfounded (Aug 9, 2013) but issued a founded "mental injury" addendum (Aug 16) and offered services; DHS later sought a CINA petition.
- Juvenile court adjudicated J.S. CINA on grounds including mental injury caused by parents; court applied clear-and-convincing standard and placed J.S. in foster care.
- Brian challenged the DHS founded child-abuse assessment and placement on the central registry; an ALJ and DHS director sustained the assessment and registry listing; the district court affirmed on judicial review.
- Brian appealed, raising three main claims: DHS violated due process (untimely statutory notice and lack of interview), the founded assessment lacked substantial evidence as to his conduct, and DHS gave undue weight to the prior CINA adjudication.
- The court affirmed: actual notice and opportunity to respond satisfied due process; substantial evidence supported DHS findings (including clinician reports and child statements); statutory authorization permits deference to CINA adjudications.
Issues
| Issue | Sydnes' Argument | DHS' Argument | Held |
|---|---|---|---|
| Due process — untimely statutory notice and no interview | DHS failed to provide written notice within five working days and did not interview him, denying meaningful opportunity to respond | Brian received actual notice (Aug 4) in time to respond; he elected to communicate in writing; statute allows offers to be declined | No constitutional violation; actual notice and written response sufficed despite statutory timing lapse |
| Substantial evidence that Brian caused mental injury | Record points to mother as primary cause; insufficient proof Brian's acts/omissions caused the diagnosed impairment | Medical reports, child statements, DHS reports, and parental conduct support causal link to Brian’s contributions | Substantial evidence supports founded assessment as to Brian (preponderance standard for DHS) |
| Use of CINA adjudication / issue preclusion | ALJ impermissibly relied on prior CINA adjudication, effectively precluding issues in the administrative proceeding | Legislature authorizes giving determinative weight to a CINA adjudication in a contested case; CINA proceeding was fully contested | DHS properly gave weight to the CINA adjudication under statutory scheme; not improper preclusion |
Key Cases Cited
- Grant v. Iowa Dep’t of Human Servs., 722 N.W.2d 169 (Iowa 2006) (agency discretion in abuse registry and preclusion discussion)
- Taylor v. Iowa Dep’t of Human Servs., 870 N.W.2d 262 (Iowa Ct. App. 2015) (scope of judicial review of DHS abuse findings)
- Meyer v. IBP, Inc., 710 N.W.2d 213 (Iowa 2006) (substantial-evidence standard on administrative facts)
- Chiodo v. Section 43.23 Panel, 846 N.W.2d 845 (Iowa 2014) (de novo review of constitutional issues)
- Koelling v. Bd. of Trs., 146 N.W.2d 284 (Iowa 1966) (due process in administrative proceedings)