State of Iowa v. Iowa District Court for Jones County, 902 N.W.2d 811

Iowa Supreme Court reviews retroactive IDOC SOTP policy change forfeiting earned time.
Statute Iowa Code § 903A.2(1)(a)(2) ambiguous on when 'required' to participate begins.
Holm v. State (Iowa 2009) held no forfeiture of accrued earned time upon SOTP refusal, only halted accrual.
In 2016 IDOC retroactively changed interpretation to forfeit pre-existing earned time; Miller delayed release.
District court ruled Holm governs; retroactive forfeiture violates Ex Post Facto; writ of certiorari granted.
Court adopts Holm interpretation and annuls the writ, requiring credit for pre-referral earned time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Holm controls the statutory interpretation	Miller argues Holm controls and prevents forfeiture.	IDOC contends Holm should be overruled due to ambiguity.	Holm controls; cannot forfeit earned time accrued before removal.
Whether retroactive application violates Ex Post Facto	Retroactive forfeiture violates Ex Post Facto.	Policy change is a clarification; not more onerous.	Retroactivity precluded; Ex Post Facto concerns resolved by Holm.
Whether the district court properly credited Miller with pre-removal earned time	Credit should be restored for earned time accrued prior to removal.	Policy aims to forfeit; no retroactive restoration.	Yes; Miller must be credited for earned time accrued before removal.

Holm v. State, 767 N.W.2d 409 (Iowa 2009) (earn ed time halted upon SOTP refusal without forfeiture of accrued time)
Reilly v. Iowa Dist. Ct., 783 N.W.2d 490 (Iowa 2010) (removal from SOTP stops accrual but preserves accrued time)
Dykstra v. Iowa Dist. Ct., 783 N.W.2d 473 (Iowa 2010) (interpretation of 2005 amendment; accrual rules)
State v. Allensworth, 823 N.W.2d 411 (Iowa 2012) (earn ed time reductions for good conduct; statutory interpretation)
State v. Thompson, 836 N.W.2d 470 (Iowa 2013) (avoid constitutional infirmities in statutory construction)