Jacobs v. Iowa Dep't of Transp., Motor Vehicle Div.
Citation | 887 N.W.2d 590 |
Decision Date | 18 November 2016 |
Docket Number | No. 16–0133.,16–0133. |
Parties | Blake James JACOBS, Appellant, v. IOWA DEPARTMENT OF TRANSPORTATION, MOTOR VEHICLE DIVISION, Appellee. |
Court | United States State Supreme Court of Iowa |
Shaun Thompson of Newman Thompson & Gray, PC, Forest City, for appellant.
Thomas J. Miller, Attorney General, and Michelle E. Rabe, Assistant Attorney General, for appellee.
A law firm electronically submitted a petition for judicial review on the last day for appeal under the statute. The next morning, the clerk's office returned the petition. The return gave two reasons: (1) the petitioner's address was missing from the electronic cover sheet and (2) the filing had not been described as a “civil-administrative appeal” on that same cover sheet. The law firm quickly completed a new electronic cover sheet and resubmitted the petition. The clerk's office accepted the petition as filed that day. However, on the respondent's motion, the district court dismissed the petition as untimely because it was one day late. The petitioner appeals.
For reasons discussed in more detail herein, we now reverse the district court. We conclude that for purposes of meeting a deadline, a filing may relate back to the original date it was received by the electronic document management system (EDMS) when the filing party demonstrates the following three conditions are met. First, the party submitted an electronic document that was received by EDMS prior to the deadline and was otherwise proper except for minor errors in the electronic cover sheet. Second, the proposed filing was returned by the clerk's office after the deadline because of these minor errors. Third, the party promptly resubmitted the filing after correcting the errors. We believe this holding gives a fair reading to our existing interim EDMS rules, as well as our statutes, other rules, and precedents.
The underlying dispute in this case relates to a one-year driver's license revocation and suspension for failure to submit to chemical testing. SeeIowa Code § 321J.9(1) (2015); see also id. § 321A.17(1). The petitioner, Blake Jacobs, contends he did not refuse testing. On September 9, 2015, an administrative law judge (ALJ) upheld Jacobs's license revocation and suspension. Jacobs timely sought interagency review, and on October 19, the Department of Transportation (DOT) filed a decision affirming the ALJ's decision.
Jacobs's counsel took steps to obtain judicial review of the DOT's ruling pursuant to Iowa Code section 17A.19. This statute requires the petition for judicial review to be filed “within thirty days after the issuance of the agency's final decision in that contested case.” Id. § 17A.19(3). November 18 was the thirtieth day. At 12:37 p.m. that day, the law firm representing Jacobs electronically submitted a petition for judicial review that was duly received by the Iowa Judicial Branch EDMS. No claim has been made that the petition itself was deficient in any way.
Jacobs appealed, and we retained the appeal.
“We review the granting of a motion to dismiss for errors at law.” Cooksey v. Cargill Meat Sols. Corp., 831 N.W.2d 94, 96 (Iowa 2013). Although we are not bound by the district court's conclusions of law, the district court's findings of fact are binding unless they are not supported by substantial evidence. McCormick v. Meyer, 582 N.W.2d 141, 144 (Iowa 1998).
District courts exercise appellate jurisdiction over agency actions on judicial review. Christiansen v. Iowa Bd. of Educ. Exam'rs, 831 N.W.2d 179, 186 (Iowa 2013). “Where a party attempts to invoke the district court's appellate jurisdiction, compliance with statutory conditions is required for the court to acquire jurisdiction.” Id. at 186–87 (quoting Anderson v. W. Hodgeman & Sons, Inc., 524 N.W.2d 418, 420 (Iowa 1994) ). Iowa Code section 17A.19(3) required Jacobs to file his petition for judicial review by November 18, 2015. If the petition was not filed until November 19, the district court had no jurisdiction to hear the case. See City of Des Moines v. City Dev. Bd., 633 N.W.2d 305, 309 (Iowa 2001) ().
The parties agree on the salient facts. Jacobs's petition was received by EDMS on November 18. Because of certain problems with the electronic cover sheet, the clerk returned the petition on November 19. Jacobs resubmitted the same petition about an hour later, presumably fixing the issues with the cover sheet. The clerk accepted the petition, and the petition received a November 19 file-stamp. The only disagreement here is legal: Should November 18 or November 19 be deemed the date when the petition was filed for purposes of Iowa Code section 17A.19(3) ?
Our court first released interim rules related to the use of electronic filing in 2007. See Iowa Supreme Ct. Order, Request for Public Comment Regarding Rules for Electronic Filing (Jan. 11, 2007). The rules are gathered in Chapter 16 of Iowa Court Rules and are available on the Iowa Judicial Branch website.See Interim Iowa Ct. R. ch. 16, http://www.iowacourts.gov (“eFiling” tab; then “overview”; then “Chapter 16, Iowa Court Rules”) (last visited Nov. 8, 2016).
These rules govern the filing of all documents in the Iowa court system as we transition to an electronic process. See Concerned Citizens, 872 N.W.2d at 401 ( ); see also Iowa Supreme Ct. Supervisory Order, In the Matter of Interim Rules to Govern the Use of the Electronic Document Management System (Mar. 1, 2012). To respond to issues that have arisen during this transition to an electronic filing system, we have periodically revised the rules since their initial 2007 release.1
Despite their temporary and evolving nature, the interim rules of electronic filing prescribed by our court “prevail over any other laws or court rules that specify the method, manner, or format for sending, receiving, retaining, or creating paper records relating to the courts.” Iowa Code § 602.1614(4). Nonetheless, when the interim rules are silent on a matter, or when a statute or other rule does not relate to “the method, manner, or format for sending, receiving, retaining, or creating paper records,” we must follow the statute or other rule.
A number of interim rules are potentially relevant to this case. Rule 16.201 defines “electronic filing” as “the electronic transmission of a document to [EDMS] together with the production and transmission of a notice of electronic filing.” Interim Iowa Ct. R. 16.201. Rule 16.307(2) is similar but worded slightly differently. It says, “The electronic transmission of a document to [EDMS] consistent with the procedures specified in these rules, together with the production and transmission of a notice of electronic filing[,] constitutes filing of the document.” Id. r. 16.307(2).
The interim rules also define “notice of electronic filing.” This means “a document generated by [EDMS] when a document is electronically filed.” Id. r. 16.201.
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