State of Iowa v. Iowa District Court for Jones County
2016 Iowa Sup. LEXIS 114
| Iowa | 2016Background
- Anthony Irvin pled guilty to two counts of domestic abuse assault after sexual-abuse charges were dismissed as part of a plea deal; sentencing did not require sex-offender registration or find sexual motivation.
- IDOC reviewers relied on the original sexual-abuse charge, the minutes of testimony, and a police report containing the victim’s near-contemporaneous written statement to refer Irvin for mandatory Sex Offender Treatment Program (SOTP).
- Irvin was given administrative notice and an opportunity for a hearing; he initially waived, then later proceeded to an evidentiary hearing before an IDOC administrative law judge (ALJ).
- At the ALJ hearing Irvin testified and admitted a sexual-component to the assault; the ALJ found the victim’s written statement credible and required SOTP; the warden affirmed.
- The district court reversed, relying on a Court of Appeals decision (Lindsey) and Stenzel, concluding IDOC cannot base SOTP referrals on unproven minutes/police reports; IDOC sought certiorari to the Iowa Supreme Court.
- The Iowa Supreme Court granted certiorari and considered whether IDOC may use a victim’s police-report statement to initially refer an inmate to SOTP and whether the ALJ could require SOTP based on that statement plus inmate admissions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May IDOC rely on victim’s police-report statement/minutes to initially refer a non-sex-offense inmate to SOTP? | Lindsey/district court: IDOC may not rely on unproven minutes/charges to classify for SOTP. | IDOC: victim statement in police report is reliable hearsay for initial referral; referral is preliminary and subject to due process. | Yes. IDOC may rely on a detailed victim statement in a police report for initial referral, so long as an evidentiary hearing is available. |
| Can an ALJ require SOTP based on the victim’s statement plus the inmate’s hearing testimony and guilty plea? | Irvin: reliance on unadmitted allegations violates due process; minutes/hearsay shouldn’t justify mandatory SOTP. | IDOC: ALJ may consider hearsay and inmate’s admissions under the low "some evidence" standard. | Yes. ALJ may rely on victim’s statement combined with Irvin’s admissions and plea to satisfy the "some evidence" standard. |
| Did IDOC satisfy procedural due process in classifying Irvin for SOTP? | Irvin: classification based on unproven facts deprived him of liberty without required protections. | IDOC: Wolff procedures were followed (notice, hearing, impartial ALJ, written findings). | No due process violation; Wolff/Dykstra protections were provided and satisfied. |
| Is Lindsey controlling and should Stenzel bar use of minutes/ police reports here? | Lindsey/district court: constrained use of minutes and Stenzel’s concerns about unproven facts apply, so IDOC erred. | IDOC: Lindsey misapplied trial evidentiary limits to prison administrative proceedings; Stenzel is distinguishable (civil commitment trial). | Lindsey was rejected; Stenzel is distinguishable—trial evidentiary rules do not control IDOC administrative SOTP hearings. |
Key Cases Cited
- Dykstra v. Iowa Dist. Court, 783 N.W.2d 473 (Iowa 2010) (IDOC has broad discretion to require SOTP but must provide Wolff procedural protections for non-sex-offense convictions)
- In re Detention of Stenzel, 827 N.W.2d 690 (Iowa 2013) (expert testimony relying on unproven minutes inadmissible in civil-commitment SVP trial; court distinguishes commitment trials from prison admin proceedings)
- Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural due process standards for prison disciplinary proceedings: notice, ability to call witnesses, impartial decisionmaker, written findings)
- McKune v. Lile, 536 U.S. 24 (2002) (recognition of rehabilitative purpose of sex-offender treatment programs)
- Superintendent v. Hill, 472 U.S. 445 (1985) ("some evidence" standard satisfies due process for prison disciplinary decisions)
- Backstrom v. Iowa Dist. Ct., 508 N.W.2d 705 (Iowa 1993) (adoption of "some evidence" standard for prison disciplinary factual findings)
- Gwinn v. Awmiller, 354 F.3d 1211 (10th Cir. 2004) (upholding prison classification based on victim’s detailed written account where inmate received Wolff protections)