Des Moines Midwife Collective, LLC v. Iowa Health Facilities Council
756 F.Supp.3d 722
S.D. Iowa2024Background
- Plaintiffs (Des Moines Midwife Collective, LLC and Caitlin Hainley) sought to open a freestanding birth center in Iowa, which would provide midwife-supported births outside hospitals or homes.
- Iowa law requires a Certificate of Need (CON) for the establishment of new healthcare facilities, including birth centers.
- Plaintiffs claimed the CON requirement is an unconstitutional barrier preventing their facility from opening, but had not formally applied for or been denied a CON.
- Plaintiffs challenged the law under the Due Process and Equal Protection Clauses of the U.S. and Iowa Constitutions, arguing it failed rational basis review.
- Both parties filed cross-motions for summary judgment.
- The court reviewed the record in light of prior precedent (notably, Birchansky), summarized both parties’ positions, and applied rational basis review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rational basis for CON law | CON is not rationally related to any legitimate government interest, only serves economic protectionism. | CON protects quality/viability of full-service hospitals, ties to public health. | CON law is rationally related to legitimate interest; survives rational basis review. |
| Substantive due process | CON law improperly burdens their liberty interests without sufficient justification. | Liberty interests claimed are not fundamental; rational basis satisfied. | No violation; rational basis review satisfied. |
| Equal protection (treatment of centers vs. others) | Differential treatment of birth centers vs. home births/expanded hospitals is irrational. | Differences in regulation and facility type justify regulatory distinctions. | No violation; distinctions rationally related to interests. |
| Iowa constitutional claims | Iowa constitution offers more protection, demanding higher scrutiny. | Iowa uses same rational basis test as federal law; plaintiffs cannot prevail. | No greater protection; claims fail for same reasons. |
Key Cases Cited
- United States v. Carolene Prods. Co., 304 U.S. 144 (rational basis review for business regulation established; legislative factual basis need not be proven)
- FCC v. Beach Commc’ns, Inc., 508 U.S. 307 (rational basis review is extremely deferential to legislative choice)
- Birchansky v. Clabaugh, 955 F.3d 751 (upholding Iowa’s CON law; rational basis satisfied for protecting full-service hospitals)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard explained: must be no genuine issue of material fact)
- Heller v. Doe ex rel. Doe, 509 U.S. 312 (statute presumed constitutional, challenger must refute all conceivable rational bases)