Michael Savala v. State of Iowa, Iowa Department of Corrections, and Jerry Bartruff, Individually and In His Official Capacity, 982 N.W.2d 667

Plaintiff Michael Savala sued the State of Iowa, the Iowa Department of Corrections, and its director for employment discrimination under the Iowa Civil Rights Act (claims: age, race, color, national origin).
On the morning of trial Savala objected to the jury venire, alleging systematic underrepresentation of Latinos, and requested two years of juror-source data to support a fair-cross-section challenge.
The district court denied both the venire challenge and the data request, concluding the federal fair-cross-section requirement does not apply to civil jury trials.
The case went to trial and the jury ruled for the defendants; Savala appealed claiming the Fifth and Seventh Amendments require civil juries be drawn from a fair cross section of the community.
The Iowa Supreme Court reviewed de novo and affirmed: it declined to extend Sixth-Amendment-style fair-cross-section doctrine to civil trials, found Thiel relied on supervisory (not constitutional) authority, and noted Savala did not assert Fourteenth Amendment incorporation; the Seventh Amendment is not fully incorporated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Constitution requires civil jury pools to reflect a fair cross section of the community	Savala: Fifth and Seventh Amendments impose a fair-cross-section requirement on civil juries analogous to the Sixth Amendment in criminal cases	Defendants: Supreme Court fair-cross-section doctrine is rooted in the Sixth Amendment and applies only to criminal prosecutions; no analogous civil right exists	Court: No—federal fair-cross-section jurisprudence applies to criminal prosecutions; it will not recognize a new civil right under the Fifth or Seventh Amendments
Whether Fifth/Seventh Amendment claims apply against a state without Fourteenth Amendment incorporation	Savala: Fifth/Seventh provide the asserted protection	Defendants: Those amendments apply to federal action; incorporation via Fourteenth is required for state action; Savala did not plead Fourteenth claims and Seventh is not fully incorporated	Court: Claims fail—Fifth/Seventh do not directly bind states; incorporation was not asserted and Seventh Amendment is not fully incorporated

Taylor v. Louisiana, 419 U.S. 522 (establishes Sixth Amendment fair-cross-section rule in criminal cases)
Duren v. Missouri, 439 U.S. 357 (framework for proving systematic exclusion from juries in criminal cases)
Thiel v. Southern Pac. Co., 328 U.S. 217 (civil jury-list exclusion decision based on supervisory power over federal courts, not constitutional holding)
Berghuis v. Smith, 559 U.S. 314 (describing Sixth Amendment’s scope to criminal prosecutions)
McDonald v. City of Chicago, 561 U.S. 742 (discusses incorporation and notes Seventh Amendment is not fully incorporated)
Timbs v. Indiana, 139 S. Ct. 682 (explains incorporation of Bill of Rights protections via Fourteenth Amendment generally applies only to some rights)
Barron v. Mayor of Baltimore, 32 U.S. 243 (historical rule that Bill of Rights originally constrained only federal government)
Walker v. Sauvinet, 92 U.S. 90 (early recognition that states retain their own regulation of civil trials regarding Seventh Amendment)