Teresa Karen Bearinger v. Iowa Department of Transportation, Motor Vehicle Division
2014 Iowa Sup. LEXIS 24
| Iowa | 2014Background
- Bearinger's license was revoked for a positive urine test showing prescription drugs after a driving incident.
- The ALJ found the prescription-drug defense (321J.2(11)) established, but held it inapplicable to license revocation proceedings.
- IDOT argued the defense only applies to criminal charges and not administrative revocations.
- Bearinger presented physician testimony that the medications were prescribed and taken as directed, with no alcohol involved.
- The district court affirmed; the supreme court reversed, holding the prescription-drug defense applies in revocation proceedings and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the prescription-drug defense applies in license revocation proceedings | Bearinger (Bearinger) argues 321J.2(11) applies to revocation | IDOT contends the defense is only for criminal charges | Yes, applies in revocation proceedings |
| How to interpret 321J.12(1) and 321J.13(2) to accommodate the defense | Statutory text supports applying 321J.2(11) to revocation | Revocation grounds operate independently of 321J.2(11) | Reading together shows defense applies to revocation and cannot render provisions surplusage |
| Whether record supports application of the defense | Bearinger testified prescription meds were taken as prescribed and caused no impairment | IDOT presented concerns about self-medication and impairment | Yes; substantial evidence supports the ALJ's finding of the defense |
Key Cases Cited
- Ludtke v. Iowa Dep’t of Transp., 646 N.W.2d 62 (Iowa 2002) (we review license decisions under Iowa Code chapter 17A; substantial evidence standard applies to agency findings)
- Welch v. Iowa Dep’t of Transp., 801 N.W.2d 590 (Iowa 2011) (de novo review of statutory interpretation; limits deference to agency’s interpretation)
- Comried v. State, 693 N.W.2d 773 (Iowa 2005) (interpretation of chapter 321J; avoid absurd results; liberal construction to protect public safety)
- Schories v. State, 827 N.W.2d 659 (Iowa 2013) (prescription-drug defense evaluated in context of driving with prescribed meds)
- Shell Oil Co. v. Iowa Com. Underground Storage Tank Fund Bd., 606 N.W.2d 376 (Iowa 2000) (last preceding antecedent doctrine and statutory interpretation guidance)
- State v. Vogel, 548 N.W.2d 584 (Iowa 1996) (purpose of Chapter 321J is public safety; interpret to minimize driving hazards)
- State v. Pickett, 671 N.W.2d 866 (Iowa 2003) (avoid surplusage in statutory interpretation)