Judicial Branch and State Court Administrator v. Iowa District Court for Linn County
800 N.W.2d 569
| Iowa | 2011Background
- Judicial Branch and State Court Administrator sought certiorari to review a Linn County district court order removing four dismissed charges from ICIS and Iowa Courts Online.
- District court had expunged the four dismissed charges from DPS/DICIS, Linn County Sheriff, Linn County Attorney, and Cedar Rapids Police records, but not FBI.
- AG argued the ICIS docket and related public docket were public records and should be removed per 692.17(1); 692.17(2)(a) requires source documents retained.
- J.W. argued 692.17(1) requires removal from the judicial docket and, alternatively, that equal protection requires removal for acquittals/dismissals.
- Court held 692.17(1) does not require removal from ICIS/Iowa Courts Online, and the Iowa Constitution’s equal protection claim fails.
- Court emphasized dockets are public records and must be maintained; public access to docket should be preserved while not removing deferred judgments from public access.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 692.17 require removal from ICIS/Iowa Courts Online? | 692.17 requires removal of disposition data after acquittal/dismissal. | Court docket is public and should not be purged; 692.17(2) preserves source documents. | No; 692.17(1) does not require removal from ICIS/Iowa Courts Online. |
| Does removal violate equal protection under the Iowa Constitution? | Public access disparate between acquittals/dismissals and deferred judgments. | Rational basis governs; classifications are permissible to promote rehabilitation and public access. | No; equal protection claim rejected; rational basis supports the distinction. |
Key Cases Cited
- Cedar Rapids v. James Props., Inc., 701 N.W.2d 673 (Iowa 2005) (public records and access considerations in public bodies)
- In re Det. of Williams, 628 N.W.2d 447 (Iowa 2001) (equal protection considerations in public access of records)
- Wright v. Iowa Dep’t of Corr., 747 N.W.2d 213 (Iowa 2008) (equal protection rational-basis framework for classifications)
- Linder v. Eckard, 261 Iowa 216 (Iowa 1967) (definition and scope of public records)
- Des Moines Register & Tribune Co. v. Osmundson, 248 N.W.2d 493 (Iowa 1976) (public access to court records and public records doctrine)
- Northwestern Bell Tel. Co. v. Hawkeye State Tel. Co., 165 N.W.2d 771 (Iowa 1969) (statutory interpretation and harmonization principles)