Baldwin v. City of Estherville
Decision Date | 29 June 2018 |
Docket Number | No. 17-1592,17-1592 |
Citation | 915 N.W.2d 259 |
Parties | Gregory BALDWIN, Appellee, v. CITY OF ESTHERVILLE, Iowa ; Matt Reineke, Individually and in his Official Capacity as an officer of the Estherville Police Department; and Matt Hellickson, Individually and in his Official Capacity as an officer of the Estherville Police Department, Appellant. |
Court | Iowa Supreme Court |
Douglas L. Phillips and René Charles LaPierre of Klass Law Firm, LLP, Sioux City, for appellants.
Jack Bjornstad of Jack Bjornstad Law Office, Okoboji, for appellee.
Thomas J. Miller, Attorney General, Jeffrey S. Thompson, Solicitor General, Julia S. Kim, Assistant Attorney General, for amicus curiae State of Iowa.
Thomas M. Boes and Catherine M. Lucas of Bradshaw, Fowler, Proctor & Fairgrave, P.C., Des Moines, for amicus curiae Iowa Communities Assurance Pool.
Katie Ervin Carlson of Fiedler & Timmer, P.L.L.C., Johnson, Jessica Zupp of Zupp and Zupp Law Firm, P.C., Denison, and Joel E. Fenton, Law Offices of Joel E. Fenton, PLC, Des Moines, for amicus curiae Iowa Association for Justice.
After receiving citizen complaints about the operation of an ATV within city limits, police officers reviewed a video of the event, examined the city’s ordinances, and concluded an ordinance had been violated. They sought and obtained an arrest warrant from a magistrate and arrested the ATV operator. An Iowa district court later dismissed the criminal case against the operator, however, finding that no ordinance actually prohibited his conduct.
Thereafter, the ATV operator brought damages claims against the city and the police officers for common-law false arrest, deprivation of civil rights under 42 U.S.C. § 1983 (2012) based on a violation of the Fourth Amendment, and directly under article I, sections 1 and 8 of the Iowa Constitution. The case was removed to federal court, where the federal district court granted summary judgment to the defendants on the common law and federal constitutional claims. The federal district court reasoned that the police officers were acting pursuant to a facially valid warrant, and it was not clearly established that the ATV operator’s conduct did not violate an ordinance.
We have now been asked by the federal district court to answer the following certified question of Iowa law relating to the Iowa constitutional claims: "Can a defendant raise a defense of qualified immunity to an individual’s claim for damages for violation of article I, § 1 and § 8 of the Iowa Constitution ?"
For the reasons discussed herein, we answer this question as follows: A defendant who pleads and proves as an affirmative defense that he or she exercised all due care to conform with the requirements of the law is entitled to qualified immunity on an individual’s claim for damages for violation of article I, sections 1 and 8 of the Iowa Constitution.
When we answer a certified question, we rely upon the facts provided with the certified question. See Bd. of Water Works Trs. of Des Moines v. Sac Cty. Bd. of Supervisors , 890 N.W.2d 50, 53 (Iowa 2017) ; Life Inv’rs Ins. Co. of Am. v. Estate of Corrado , 838 N.W.2d 640, 643 (Iowa 2013). Accordingly, we restate the facts as set forth by the federal district court:
Baldwin v. Estherville , 218 F.Supp.3d 987, 992–93 (N.D. Iowa 2016) (omissions in original) (footnote omitted).
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