Kim Schmett and Leanne Pellett v. State Objections Panel and Abby for Iowa, 973 N.W.2d 300

Abby Finkenauer filed a U.S. Senate nominating petition on March 10, 2022; Iowa law requires at least 100 valid signatures in each of at least 19 counties.
Electors Kim Schmett and Leanne Pellett objected, alleging multiple defects including three signatures with missing or incorrect dates.
At a March 29 State Objections Panel hearing, the Panel sustained many objections but, by 2–1 vote, overruled objections to the three signatures lacking/with an incorrect date (one in Allamakee County, two in Cedar County), leaving Finkenauer just above the county thresholds.
The district court granted expedited judicial review, found objectors had standing, and held the undated/incorrectly dated signatures invalid under Iowa Code §43.15(2), reversing the Panel.
The Iowa Supreme Court reviewed whether the 2021 amendment to Iowa Code §43.24(1)(a) — specifying that private objections relating to incorrect/incomplete information required under §43.14 or §43.18 shall be sustained — displaces §43.15’s date requirement for purposes of outside-party objections; the court held the amendment controls and reversed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether missing or incorrect dates on petition signature lines require the signatures to be disqualified such that the candidate fails ballot-qualification thresholds	Schmett & Pellett: §43.15(2) mandates each signer add the date; failure is noncompliant and signature must be invalidated	State Panel & Abby for Iowa: §43.14(2)(c) lists the grounds for not counting a signature and does not include missing/incorrect dates; §43.24(1)(a) (2021 amendment) limits private objections to errors in §43.14/43.18 only	The 2021 amendment to §43.24(1)(a) prevails; private objections are sustainable only for incorrect/incomplete information required under §43.14 or §43.18 (which do not include dates), so the Panel correctly counted the three signatures

Chiodo v. Section 43.24 Panel, 846 N.W.2d 845 (Iowa 2014) (treated Panel determinations as subject to judicial review under chapter 17A for purposes of expedited election litigation)
In re C.Z., 956 N.W.2d 113 (Iowa 2021) (applies the canon that later statutes control when irreconcilable)
Iowa Right to Life Comm., Inc. v. Tooker, 808 N.W.2d 417 (Iowa 2011) (statutory interpretation principles concerning legislative intent and statutory construction)
State v. Hall, 969 N.W.2d 299 (Iowa 2022) (recognizes meaning can be expressed by omission as well as inclusion)
Ferguson v. Exide Techs., Inc., 936 N.W.2d 429 (Iowa 2019) (when legislature creates and defines a private remedy, the remedy is generally exclusive)