State of Iowa v. Brian Patrick Clemens, 903 N.W.2d 347

In May 2011 Clemens was charged in two separate proceedings: a multicount trial information (AGIN107785) with several aggravated misdemeanors and a separate simple-misdemeanor complaint (SMSM168241) for domestic abuse assault.
Counts were split into separate case numbers because simple misdemeanors follow different procedure and are not indictable.
Clemens pled guilty in AGIN107785 to third-degree harassment (a lesser-included offense); several other counts including the SMSM168241 misdemeanor were dismissed as part of plea/deferred-prosecution agreements.
After Iowa enacted a statutory expungement scheme (Iowa Code § 901C.2), Clemens moved in 2016 to expunge the dismissed SMSM168241 record; the State opposed.
Magistrate and district court denied expungement reasoning the dismissed misdemeanor was factually related to the conviction in the other prosecution and thus part of the same “criminal case.”
The Iowa Supreme Court reversed, holding “case” in § 901C.2 refers to a single numbered legal proceeding and remanded for expungement proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does “criminal case” in Iowa Code § 901C.2 mean a single numbered legal proceeding or all charges arising from the same transaction?	(State) “Case” covers all charges arising from the same incident; factually related dismissed charges are part of the same case.	(Clemens) “Case” means a particular case number/legal proceeding; separate docket numbers may be expunged independently.	The court held “case” means a particular numbered legal proceeding; Clemens entitled to expunge SMSM168241.
Should factual relatedness prevent expungement when charges were prosecuted separately by case number?	(State) Treating separately filed but factually related charges as separate for expungement is arbitrary and could mislead public understanding.	(Clemens) A case-number rule is administrable, consistent with statutory drafting and legislative history, and protects against public stigma from separate docket entries.	Court favored administrability, legislative history, and stigma concerns; factual relatedness alone does not defeat expungement of a separately numbered proceeding.

Judicial Branch v. Iowa Dist. Ct., 800 N.W.2d 569 (Iowa 2011) (prompted legislative response re: removal of dismissed-case records)
State v. Basinger, 721 N.W.2d 783 (Iowa 2006) (treated “case” as a numbered proceeding for taxing costs)
State v. McFarland, 721 N.W.2d 793 (Iowa 2006) (applied one-fee-per-case rule across numbered proceedings)
Stoddard v. State, 911 A.2d 1245 (Md. 2006) (expungement may depend on whether charges arise from same incident; discussed unit concept)
State v. Pariag, 998 N.E.2d 401 (Ohio 2013) (Ohio bars sealing of dismissed charge if it arises from same act supporting a conviction)
State v. Bobola, 138 A.3d 519 (N.H. 2016) (treated separately docketed assault theories as related when same conduct/trial theory)