Jacobs v. Iowa Dep't of Transp., Motor Vehicle Div., No. 16–0133.

CourtUnited States State Supreme Court of Iowa
Writing for the CourtMANSFIELD, Justice.
Citation887 N.W.2d 590
Parties Blake James JACOBS, Appellant, v. IOWA DEPARTMENT OF TRANSPORTATION, MOTOR VEHICLE DIVISION, Appellee.
Decision Date18 November 2016
Docket NumberNo. 16–0133.

887 N.W.2d 590

Blake James JACOBS, Appellant,
v.
IOWA DEPARTMENT OF TRANSPORTATION, MOTOR VEHICLE DIVISION, Appellee.

No. 16–0133.

Supreme Court of Iowa.

Nov. 18, 2016.


887 N.W.2d 591

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.

MANSFIELD, Justice.

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.

I. Background Facts and Proceedings.

The underlying dispute in this case relates to a one-year driver's license revocation and suspension for failure to submit to chemical testing. See

887 N.W.2d 592

Iowa 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.

The next morning, at 8:58 a.m., the Winnebago County Clerk of the District Court sent a message to Jacobs's counsel that his petition had been “Returned Not Filed.” The message gave the following reason: “Please fill out all of your client info (address) in the Service List. This kind of case is called Civil–Administrative Appeal too. Then re-submit. Thanks.” The message did confirm that the submission had occurred on November 18 (the previous day) at 12:37 p.m. and had been designated “Civil—Other Actions” rather than “Civil—Administrative Appeal.”

After receiving this message, the law firm added the petitioner's address and corrected the category from “Other Actions” to “Administrative Appeal” on the electronic cover sheet found on the EDMS website. No changes were made to the petition itself. The law firm then resubmitted the petition to EDMS. The petition was electronically file-stamped by the clerk of court that same morning and read: “E–FILED 2015 NOV. 19 9:53 AM WINNEBAGO—CLERK OF DISTRICT COURT.”

DOT appeared in the proceeding and filed a motion to dismiss, urging that Jacobs had failed to file his petition within the thirty-day deadline set forth in Iowa Code section 17A.19(3). Jacobs countered with a resistance supported by an affidavit and exhibits. Following a telephonic hearing, the district court dismissed Jacobs's petition. The court determined that the petition was not “officially and properly filed” with the clerk's office until 9:53 a.m. on November 19 and, therefore, the court lacked jurisdiction to hear the appeal. In reaching its decision, the district court relied upon our recent opinion in Concerned Citizens of Southeast Polk School District v. City Development Board of State, 872 N.W.2d 399 (Iowa 2015). The court reasoned that although the petition had been submitted by Jacobs on November 18, the court could not “identify any reason to give the date and time of the original submission any priority over the file-stamp placed on the petition.... [W]ithout the electronic filing stamp, it seems a document is not officially filed.” The district court also noted there was no indication that the clerk of court had not been “expeditious in reviewing the filing.”

Jacobs filed a motion to enlarge or amend the district court's order of dismissal. The district court denied the motion and added,

The fact that the original submission was rejected on day 31 is not particularly relevant in this case, the facts are simply that the submission was not file-stamped on the 30th day, through no fault of the clerk or EDMS. When facing a deadline, the filer has the responsibility to ensure that the filing is accepted
887 N.W.2d 593
and file-stamped before the deadline has passed.

Jacobs appealed, and we retained the appeal.

II. Standard of Review.

“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).

III. Analysis.

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) (“A timely petition for judicial review from an administrative decision is a jurisdictional prerequisite.”).

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 (noting that the clerk of court “remains the depository of court records” and the rules change only “the means of transacting business” in an electronic medium); 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

887 N.W.2d 594

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...

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10 practice notes
  • State v. Iowa Dist. Court for Scott Cnty., No. 15-1255
    • United States
    • United States State Supreme Court of Iowa
    • January 20, 2017
    ...is also important. Generally, we try to interpret statutes so they are reasonable and workable. Jacobs v. Iowa Dep't of Transp. , 887 N.W.2d 590, 597 (Iowa 2016) (recognizing that we "interpret our statutes ... so they effectuate just and reasonable results, not arbitrary ones"); ......
  • Askvig v. Snap-On Logistics Co., 20–0997
    • United States
    • United States State Supreme Court of Iowa
    • December 17, 2021
    ...Standard of Review."We review the granting of a motion to dismiss for errors at law." Jacobs v. Iowa Dep't of Transp. , 887 N.W.2d 590, 593 (Iowa 2016) (quoting Cooksey v. Cargill Meat Sols. Corp. , 831 N.W.2d 94, 96 (Iowa 2013) ).IV. Legal Analysis. Iowa Code section 17A.19(3) go......
  • Askvig v. Snap-On Logistics Co., 20-0997
    • United States
    • United States State Supreme Court of Iowa
    • December 17, 2021
    ...III. Standard of Review. "We review the granting of a motion to dismiss for errors at law." Jacobs v. Iowa Dep't of Transp., 887 N.W.2d 590, 593 (Iowa 2016) (quoting Cooksey v. Cargill Meat Sols. Corp., 831 N.W.2d 94, 96 (Iowa 2013)). IV. Legal Analysis. Iowa Code section 17A.19(3......
  • Toney v. Parker, No. 19-2121
    • United States
    • United States State Supreme Court of Iowa
    • April 16, 2021
    ...its discretion by granting the motion to strike.We addressed a similar timeliness issue in Jacobs v. Iowa Department of Transportation , 887 N.W.2d 590 (Iowa 2016). Jacobs's driver's license had been revoked and suspended for failure to submit to chemical testing. Id. at 591. Jacobs contend......
  • Request a trial to view additional results
10 cases
  • State v. Iowa Dist. Court for Scott Cnty., No. 15-1255
    • United States
    • United States State Supreme Court of Iowa
    • January 20, 2017
    ...is also important. Generally, we try to interpret statutes so they are reasonable and workable. Jacobs v. Iowa Dep't of Transp. , 887 N.W.2d 590, 597 (Iowa 2016) (recognizing that we "interpret our statutes ... so they effectuate just and reasonable results, not arbitrary ones"); ......
  • Askvig v. Snap-On Logistics Co., 20–0997
    • United States
    • United States State Supreme Court of Iowa
    • December 17, 2021
    ...Standard of Review."We review the granting of a motion to dismiss for errors at law." Jacobs v. Iowa Dep't of Transp. , 887 N.W.2d 590, 593 (Iowa 2016) (quoting Cooksey v. Cargill Meat Sols. Corp. , 831 N.W.2d 94, 96 (Iowa 2013) ).IV. Legal Analysis. Iowa Code section 17A.19(3) go......
  • Toney v. Parker, No. 19-2121
    • United States
    • United States State Supreme Court of Iowa
    • April 16, 2021
    ...its discretion by granting the motion to strike.We addressed a similar timeliness issue in Jacobs v. Iowa Department of Transportation , 887 N.W.2d 590 (Iowa 2016). Jacobs's driver's license had been revoked and suspended for failure to submit to chemical testing. Id. at 591. Jacobs contend......
  • Askvig v. Snap-On Logistics Co., 20-0997
    • United States
    • United States State Supreme Court of Iowa
    • December 17, 2021
    ...III. Standard of Review. "We review the granting of a motion to dismiss for errors at law." Jacobs v. Iowa Dep't of Transp., 887 N.W.2d 590, 593 (Iowa 2016) (quoting Cooksey v. Cargill Meat Sols. Corp., 831 N.W.2d 94, 96 (Iowa 2013)). IV. Legal Analysis. Iowa Code section 17A.19(3......
  • Request a trial to view additional results

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