Eagle Rise Development, LLC, Troy Scott Wilbur and Alexander Scott Wilbur v. Iowa District Court for Clinton County, 24-1331

The City of Clinton sought contempt sanctions after Eagle Rise failed to comply with an abatement order requiring roof repairs and other code corrections. 1
The magistrate’s first contempt order against Eagle Rise was purged after the company paid the penalty and addressed the vacant-property registration, but the roof dispute remained. 2
For the second contempt proceeding, the City tried ten times to personally serve Eagle Rise and its member-managers, then obtained permission for publication service after the court found evasion. 3
The City published notice but did not mail a copy to Eagle Rise, Troy, or Alexander, and Troy appeared at the hearing only after learning of it the day before. 4
The magistrate held Eagle Rise, Troy, and Alexander in contempt and imposed jail and fines on Troy and Alexander individually. 5
The court of appeals upheld the contempt order as to Troy and Eagle Rise but vacated it as to Alexander; the supreme court granted further review. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was section 665.7 notice a subject-matter jurisdiction requirement? 7	Petitioners said lack of personal service deprived jurisdiction.	The City said the statute limited only authority, not jurisdiction.	No; it limited authority, not subject-matter jurisdiction. 8
Could Troy and Alexander be held in contempt without being named in the show-cause order? 9	Petitioners said they lacked individual notice as offenders.	The City said service on Eagle Rise and Troy’s appearance sufficed.	No; they were not personally noticed as contemnors. 10
Was Eagle Rise given a reasonable time to respond to the show-cause order? 11	Eagle Rise said one-day notice and no mailed copy were inadequate.	The City said publication and Troy’s appearance waived any defect.	No; Eagle Rise lacked a reasonable time to prepare. 12

Spitz v. Iowa Dist. Ct. for Mitchell Cnty., 881 N.W.2d 456 (Iowa 2016) (certiorari and contempt reviewed for errors at law; contempt is quasi-criminal 13)
City of Dubuque v. Iowa Dist. Ct. for Dubuque Cnty., 725 N.W.2d 449 (Iowa 2006) (certiorari review standard for contempt findings 14)
State v. Pagliai, 30 N.W.3d 226 (Iowa 2026) (distinguishes subject-matter jurisdiction from authority to act 15)
State v. Rutherford, 997 N.W.2d 142 (Iowa 2023) (statutory limits on judicial authority are not jurisdictional 16)
Franklin v. State, 905 N.W.2d 170 (Iowa 2017) (a court may have subject-matter jurisdiction yet lack authority in a particular case 17)
Lutz v. Darbyshire, 297 N.W.2d 349 (Iowa 1980) (contempt power is essential and notice limits the court’s power to punish 18)
Knox v. Mun. Ct. of City of Des Moines, 185 N.W.2d 705 (Iowa 1971) (civil contempt is quasi-criminal and requires notice and opportunity to defend 19)
Opperman v. Sullivan, 330 N.W.2d 796 (Iowa 1983) (prior personal jurisdiction in the main case does not excuse contempt notice 20)
Beauchamp v. Iowa Dist. Ct. in & for Cass Cnty., 328 N.W.2d 527 (Iowa 1983) (improper service method can defeat contempt jurisdiction/authority 21)