Upon the Petition of Kent D. Langholz
887 N.W.2d 770
| Iowa | 2016Background
- Kent (father) sought and obtained a temporary injunction (by stipulation) restraining Harold (former coach) from contacting Kent’s minor daughters; court ordered most case materials sealed.
- After a contested trial, the district court entered a permanent injunction barring Harold from communicating with the children, forbidding attendance at their extracurricular events except limited attendance when his step‑grandchildren participated, requiring avoidance of visual contact and a 100‑foot distance, and ordered the ruling sealed and accessible only to parties and counsel.
- Kent moved to allow redissemination of the district court’s ruling and to expand the injunction (bar Harold from the mother’s home and all games). Harold moved to prohibit redissemination and to eliminate the 100‑foot provision.
- The district court denied modification/expansion, allowed parties to communicate only that an injunction exists (and the 100‑foot rule), kept the ruling sealed, but issued an unsealed writ of injunction for enforcement. Kent appealed.
- The Iowa Supreme Court held the district court erred by sealing the ruling without the hearing and findings required by the Iowa Open Records Act (Iowa Code ch. 22) when no statutory exemption under section 22.7 plainly applied; remanded for a section 22.8 hearing.
- The Supreme Court affirmed the denial of Kent’s request to expand the injunction, finding the existing injunction already addressed the harms Kent alleged and provided adequate remedies for violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly sealed and prohibited redissemination of the written ruling granting permanent injunctive relief | Kent: he agreed only to seal exhibits and routine orders, not the ruling; sealing must follow Iowa Open Records Act procedures and findings | Harold: the ruling contains child‑abuse/CPC material and minor‑related information exempt from disclosure under statutory provisions; sealing protects children’s privacy | Court: Reversed sealing — when no 22.7 exemption plainly applies, district court must hold a 22.8 hearing and make findings before sealing; remand for hearing consistent with Open Records Act |
| Whether child abuse statutes (ch. 235A) independently prohibit redissemination of the ruling | Kent: N/A (argues against sealing) | Harold: the ruling references a CPC interview and disposition and thus may implicate chapter 235A confidentiality | Court: Chapter 235A may apply to founded report data, but here the CPC determined the allegation was not founded and the district court made no findings; remand for factual findings and determination under statutory scheme |
| Whether the permanent injunction should be expanded to bar Harold from mother’s home and all games | Kent: expansion necessary because Harold could leave notes, encounter children at home or at events, and prior presence at a game harmed daughter | Harold: existing terms already prevent contact; expansion would unduly burden familial relations and punish him | Court: Affirmed denial — existing injunction (ban on in‑person contact, passing notes, 100‑foot rule, avoidance of visual contact) already addresses the alleged harms; expansion unnecessary |
| Whether the district court abused discretion by including 100‑foot proximity restriction | Harold: requested elimination of the 100‑foot rule as overly broad | Kent: (supports enforcement) | Court: Upheld the 100‑foot provision as part of a carefully drawn injunction; no abuse shown |
Key Cases Cited
- Bank of Am., N.A. v. Schulte, 843 N.W.2d 876 (Iowa 2014) (standard of review for equitable proceedings and statutory interpretation)
- Iowa Film Prod. Servs. v. Iowa Dep’t of Econ. Dev., 818 N.W.2d 207 (Iowa 2012) (Open Records Act presumption of openness)
- Burton v. Univ. of Iowa Hosps. & Clinics, 566 N.W.2d 182 (Iowa 1997) (availability of injunctive relief under Iowa Code § 22.8 and required findings)
- Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996) (treatment of statutory exemptions under § 22.7 and injunctive remedies)
- Clymer v. City of Cedar Rapids, 601 N.W.2d 42 (Iowa 1999) (privacy/disclosure balancing factors)
- Opat v. Ludeking, 666 N.W.2d 597 (Iowa 2003) (standards for scope and certainty of injunctions)
- City of Okoboji v. Parks, 830 N.W.2d 300 (Iowa 2013) (elements required for permanent injunction)
