Deborah E. McFadden, Individually and as Administrator of the Estate of Charles Walter McFadden, Jr. v. Department of Transportation, State of Iowa
2016 Iowa Sup. LEXIS 5
| Iowa | 2016Background
- Decedent Charles McFadden died in a motorcycle crash on Highway 69; Deborah McFadden was appointed administrator of his estate in June 2012.
- On October 30, 2013 Deborah submitted a tort-claim form to the State Appeal Board alleging negligent highway maintenance (steep drop-off between pavement and gravel shoulder) causing wrongful death.
- The submitted claim named "Deborah McFadden" and included the factual allegations required by the appeal-board form and rules; it did not state her capacity as administrator nor attach her appointment paperwork.
- The Appeal Board took no action within six months; Deborah withdrew the claim and filed suit in district court naming herself "Individually and as Administrator."
- The State moved to dismiss, arguing Deborah failed to exhaust administrative remedies for the estate claim because the board was not presented with a claim in her representative capacity.
- District court and court of appeals dismissed for lack of presentment; the Iowa Supreme Court granted further review and reversed, holding Deborah properly presented the claim and exhausted administrative remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff exhausted ITCA administrative remedies by presenting a claim that did not expressly state her representative capacity | McFadden: she was the administrator when she filed; the appeal-board form asked for name and other info but not capacity; her name alone sufficed to present the estate claim | DOT: the claim failed to present the estate’s claim because it did not identify her as administrator or attach appointment proof; thus no exhaustion | Held: Exhaustion satisfied — she was administrator when she filed and the claim complied with appeal-board rules; dismissal reversed |
| Whether Voss controls when claimant lacked representative capacity at time of presentment | McFadden: Voss is distinguishable because in Voss the claimant was not administrator when presenting the claim | DOT: relied on Voss to argue presentment was inadequate | Held: Voss distinguished — presentment here occurred while claimant had legal capacity, so Voss does not bar suit |
| Whether the appeal-board form and rules require explicit statement of representative capacity | McFadden: the rules require name, address, etc., not a label of representative capacity; real-party-in-interest may sue in own name | DOT: representative status is essential for wrongful-death claim presentment | Held: The rules do not require expressly stating "administrator"; claim form provided required information and was not a nullity |
| Whether strict formalism should defeat the claim where substantive info was provided | McFadden: courts should decide on merits where rules met and State had required info | DOT: procedural requirements are jurisdictional and must be enforced | Held: Balance favors substance; administrative rules were met and strict technicality did not justify dismissal |
Key Cases Cited
- In re Estate of Voss, 553 N.W.2d 878 (Iowa 1996) (failure to present claim in representative capacity may bar suit under ITCA)
- Schneider v. State, 789 N.W.2d 138 (Iowa 2010) (filing with the state appeal board is prerequisite to suits under the ITCA)
- Swanger v. State, 445 N.W.2d 344 (Iowa 1989) (exhaustion of administrative remedy is jurisdictional)
- Pearson v. Anthony, 254 N.W. 10 (Iowa 1934) (personal representative capacity is essential in wrongful-death suits)