Concerned Citizens of Southeast Polk School District and Jessman Smith v. City Development Board of the State of Iowa, 2015 Iowa Sup. LEXIS 100

Concerned Citizens sought judicial review of a City Development Board decision approving annexation; district court affirmed.
The district court’s written ruling was electronically filed and time-stamped July 11, 2014; the EDMS transmitted the notice of electronic filing (NEF) on July 15, 2014.
Concerned Citizens filed a notice of appeal on August 12 and sought an extension; the Board moved to dismiss as untimely.
Iowa appellate rule requires a notice of appeal within 30 days after the filing of the final order or judgment.
The majority held the 30-day appeal period begins on the date the judgment/order is electronically filed (the electronic file stamp date), not the NEF transmission date, and dismissed the appeal as untimely.
Two justices dissented, arguing the filing date should be the date the clerk actually processed/served the order (NEF date) given ambiguities in the EDMS interim rules and statutory provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the 30-day appeal period commence for an electronically filed district court order?	Count 30 days from transmission of the NEF (service/notice date); filing isn’t complete until NEF issued.	Count 30 days from the document’s electronic file-stamp date (date order was filed in EDMS).	30 days runs from the electronic filing date shown by the file stamp (July 11); NEF date does not postpone the deadline; appeal dismissed as untimely.

Lau v. City of Oelwein, 336 N.W.2d 202 (discusses commencement of appeal period when judgment is properly entered)
Root v. Toney, 841 N.W.2d 83 (rules governing time for appeal are jurisdictional; supervisory orders cannot conflict with statutes)
In re Marriage of Mantz, 266 N.W.2d 758 (appeal deadlines are jurisdictional)
Ahls v. Sherwood/Div. of Harsco Corp., 473 N.W.2d 619 (late appeals must be dismissed)
Doland v. Boone County, 376 N.W.2d 870 (court must refuse to entertain appeals not authorized by rules)
McCubbin Seed Farm, Inc. v. Tri-Mor Sales, Inc., 257 N.W.2d 55 (controlling date for appeal is date judgment entered by clerk)
Christiansen v. Iowa Bd. of Educ. Exam’rs, 831 N.W.2d 179 (preference to resolve disputes on their merits; interpretive principles)
Purethane, Inc. v. Iowa State Bd. of Tax Review, 498 N.W.2d 706 (appeal period begins when decision is officially available to parties)
Hines v. Ill. Cent. Gulf R.R., 330 N.W.2d 284 (new rule/version doesn’t change longstanding legal principles absent clear intent)
Janson v. Fulton, 162 N.W.2d 438 (statutes should receive sensible, practical construction)
Wilson v. Wright, 189 N.W.2d 681 (effect of clerk’s entry on filing date for appeal purposes)