David Taft v. Iowa District Court for Linn County
828 N.W.2d 309
| Iowa | 2013Background
- Taft, a civilly committed sexually violent predator under Iowa Code chapter 229A, sought a final hearing for discharge or transitional release; the district court denied.
- Taft previously committed for offenses starting in 1987, with later offenses and prison discharge in 2005.
- Annual reviews under §229A.8 require written records unless a hearing is requested; Taft requested final hearings in 2010 and 2011.
- CCUSO staff reports in 2010–2011 claimed Taft’s mental abnormality persisted and cited six disciplinary reports as grounds to disqualify him from transitional release.
- Dr. Craig Rypma, a licensed psychologist, opined Taft could be discharged or placed in transitional release; the district court weighs competing expert opinions and concluded Taft failed to rebut the presumption of continued commitment.
- Taft sought writ of certiorari; the Supreme Court of Iowa annulled the writ, affirming the district court’s outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the 2009 amendment to §229A.8(5)(e)(1) alter the standard for entitlement to a final hearing? | Taft argues no substantial change to Johnson’s framework. | State contends the amendment shifted the court’s role to require more reliable evidence. | Ambiguity exists; amendment changes gatekeeping and reliability requirements but not the burden. |
| Was the district court allowed to weigh competing expert opinions at the annual review stage? | Taft contends no mini-trial weighing; rely on Johnson framework. | State argues district court may weigh reliability of evidence. | District court erred by weighing Dr. Rypma against State experts; but the standard still requires reliable evidence. |
| Did Taft’s major discipline reports render him statutorily ineligible for transitional release? | Due process challenge to §229A.8A(2)(e) as precondition unrelated to danger. | Discipline reports directly disqualify from transitional release under statute. | Taft was ineligible for transitional release due to major discipline reports within six months. |
Key Cases Cited
- Johnson v. Iowa Dist. Ct., 756 N.W.2d 845 (Iowa 2008) (interpreted admissible evidence framework for final hearing)
- Swanson v. Civil Commitment Unit for Sex Offenders, 737 N.W.2d 300 (Iowa 2007) (describes transitional release framework)
- Ranes v. Adams Labs., Inc., 778 N.W.2d 677 (Iowa 2010) (expert testimony reliability and Rule 5.702 guidance)
- Case v. Olson, 234 Iowa 869, 14 N.W.2d 717 (Iowa 1944) (statutory interpretation can rely on canons of construction)
- IBP, Inc. v. Al-Gharib, 604 N.W.2d 621 (Iowa 2000) (weight of expert testimony discussion guidance)
- Johnson v. Knoxville Cmty. Sch. Dist., 570 N.W.2d 633 (Iowa 1997) (reliability/admissibility standard for expert testimony)