Legal Memorandum: Judicial Review of ICRC Actions in IA

Issue: Under Iowa law, does a court have jurisdiction to review the decision of the Iowa Civil Rights Commission (ICRC)?

Area of Law: Administrative Law, Administrative Law & Regulation (Federal and State), Constitutional Law, Litigation & Procedure
Keywords: Judicial review; Iowa Civil Rights Commission (ICRC)
Jurisdiction: Federal, Iowa
Cited Cases: 318 N.W.2d 162; 522 N.W.2d 82
Cited Statutes: Iowa Administrative Procedures Act (IAPA), Chapter 17A; Iowa Code § 216.17(1)(a); Iowa Code § 17A.19(8)
Date: 06/01/2015

A party dissatisfied with the decision of the Iowa Civil Rights Commission (ICRC) may seek judicial review of that decision.  Judicial review of ICRC actions is governed by the Iowa Administrative Procedures Act (IAPA), Chapter 17A.  Iowa Code § 216.17(1)(a).  Parties can seek review of final decisions within the time set in § 17A.19 and of no probable cause findings or other final agency actions within thirty days.  Id. § 216.17(1)(a), (b). 

When a district court reviews the decision of the ICRC under the IAPA, it functions as an appellate court and is limited to correcting errors of law.  Food, Inc. v. Iowa Civil Rights Comm’n, 318 N.W.2d 162, 165 (Iowa 1982) (citing Iowa Code § 17A.19(8)).  The district court does not review the ICRC actions de novo; it can only overturn the hearing officer’s determination if it was not supported by substantial evidence in the record.  Id. at 168-69.  “The district court may reverse if the agency’s decision was affected by an error of law or was unreasonable, arbitrary or capricious . . . [or] if the agency’s decision is not supported by substantial evidence. Civil Serv. Comm’n v. Iowa Civil Rights Comm’n, 522 N.W.2d 82, 85 (Iowa 1994) (citing Iowa Code § 17A.19(8)).


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