Jeremie J. Cooksey v. Cargill Meat Solutions Corporation
831 N.W.2d 94
| Iowa | 2013Background
- Cooksey sought unemployment benefits from Iowa Workforce Development after discharge by Cargill Meat Solutions.
- Administrative law judge found misconduct; EAB affirmed; Cooksey petitioned for judicial review in Polk County district court.
- Caption named Cargill as defendant; EAB was not named in the caption, though body identified EAB’s final action and attached the decision.
- Petition and attachments were timely served on the EAB; EAB moved to dismiss alleging lack of name in caption.
- District court dismissed; court of appeals affirmed; Iowa Supreme Court granted review to resolve capitalization vs. body-identified agency issues.
- Majority held petition substantially complied with 17A.19(4); jurisdiction vested and petition not subject to dismissal; remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether caption naming failure defeats jurisdiction | Cooksey argues substantial compliance exists since EAB is identified in body and served timely. | Cargill argues failure to name EAB in caption is fatal under 17A.19(4). | Petition substantially complied; jurisdiction vests; not dismissed. |
| Preservation of error on substantial compliance | Error preserved because EAB raised substantial compliance in motion and district court ruled on it. | Error not preserved if district court ruling was treated as incorporated and not contested. | Error preserved; district court ruling on substantial compliance was binding on appeal. |
| Governing standard for naming agency as respondent | Substantial compliance acceptable when body of petition identifies agency and timely notice is given. | Strict naming in caption required; substantial compliance cannot override statutory language. | Contents evaluated as a whole; substantial compliance satisfied here; caption need not name agency if body identifies it and notice is served. |
Key Cases Cited
- Frost v. S.S. Kresge Co., 299 N.W.2d 646 (Iowa 1980) (substantial compliance when misnaming agency; notice achieved)
- Buchholtz v. Iowa Department of Public Instruction, 315 N.W.2d 789 (Iowa 1982) (naming related entity may suffice without exact agency name)
- Green v. Iowa Department of Job Service, 299 N.W.2d 651 (Iowa 1980) (substantial compliance when body identifies employer; caption may omit)
- Ball v. Iowa Department of Job Service, 308 N.W.2d 54 (Iowa 1981) (dismissal required when party not named anywhere in petition)
- Iowa Department of Transportation v. Iowa District Court, 534 N.W.2d 457 (Iowa 1995) (strict compliance; misnaming agency can defeat jurisdiction under 17A.19(4))
- Lamasters v. State, 821 N.W.2d 856 (Iowa 2012) (if the court’s ruling considers the issue, preserved even with sparse reasoning)