Michael Taylor v. Iowa Department of Human Services
2015 Iowa App. LEXIS 704
| Iowa Ct. App. | 2015Background
- This appeal concerns Michael Taylor’s challenge to an Iowa DHS finding that a May 9, 2013 domestic dispute with C.E. constituted founded child abuse and placed him on the central registry.
- The district court upheld the DHS finding and placement on the registry, and Taylor appeals the ruling.
- An ALJ found that Taylor assaulted C.E., and the district court affirmed the factual findings as supported by substantial evidence.
- DHS then concluded that the assault, witnessed by G.T., violated the denial of critical care provision and thus qualified as child abuse for registry purposes.
- Taylor contested both the assault finding and the denial-of-critical-care theory, arguing the agency used outdated law and misapplied the statute.
- The Iowa Supreme Court’s interpretation of “direct harm” and “risk of harm” led to reversing the denial-of-critical-care portion and remanding for proper application of current law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there substantial evidence that Taylor assaulted C.E.? | Taylor argues credibility issues and lack of corroboration, | DHS found C.E. credible and supported by the record, | Yes; substantial evidence supports the assault finding. |
| Did DHS properly apply the denial of critical care theory to this case? | Taylor asserts DHS used outdated law and misapplied it to the facts | DHS applied statutory/administrative rules to support registry placement | No; DHS used outdated law and misapplied it, warranting remand. |
| Did the agency correctly interpret “direct harm” or “risk of harm” under the statute? | Taylor argues the proper terms were not used and the law requires direct harm or risk of harm | DHS relied on broader notions of harm | No; the language used was outdated; remand for proper law application. |
Key Cases Cited
- Doe v. Iowa Dep’t of Human Servs., 786 N.W.2d 853 (Iowa 2010) (interpretation of denial of critical care and DHS standards)
- Mauk v. Iowa Dep’t of Human Servs., 617 N.W.2d 909 (Iowa 2000) (standard of review for agency findings)
- Arndt v. City of LeClaire, 728 N.W.2d 389 (Iowa 2007) (credibility and deference to agency findings)
- Hildreth v. State, 582 N.W.2d 167 (Iowa 1998) (need for corroboration not always required in abuse cases)
- Doe, 786 N.W.2d 853 (Iowa 2010), - (Iowa 2010) (see above)