Michael Chandler, Eddie Jones, and Chad Maddison were corrections officers disciplined after administrative investigations by the Iowa Department of Corrections. They alleged that the Department violated Chapter 80F by refusing to provide copies of witness statements and investigative reports, as required by Iowa Code § 80F.1(9). The officers filed suit, seeking damages and injunctive relief, but the district court granted summary judgment to the Department, holding that Chapter 80F did not create a private right of action against state agencies. The officers appealed to the Supreme Court of Iowa.
The Court affirmed the district court’s decision, finding that peace officers could not sue their employing agency directly under Iowa’s Peace Officer, Public Safety, and Emergency Personnel Bill of Rights.
The key provision at issue, § 80F.1(13), grants officers the right to sue “any person, group of persons, organization, or corporation” for damage arising from false complaints or “any other violation of this chapter.” The plaintiffs argued that a “person” included government agencies under Iowa Code § 4.1(20), which broadly defines a “person” to encompass governmental subdivisions. However, the Court rejected this interpretation, noting that § 80F.1(13) separately listed “corporation,” rendering the plaintiffs’ reliance on § 4.1(20) redundant. “Applying the definition of ‘person’ from § 4.1(20), as the officers say we must, requires us to assume that the legislature was adding superfluous words in its list of parties who could be sued.”
The Court further observed that Chapter 80F repeatedly used the term “employing agency” elsewhere but omitted it from § 80F.1(13)’s list of potential defendants. This omission, the Court reasoned, implied the legislature did not intend to subject agencies to private suits under the statute. The Court also contrasted Chapter 80F with other Iowa statutes that explicitly authorized suits against agencies, noting the absence of similar language in Chapter 80F.
The Court next addressed whether the officers could bypass Iowa’s Administrative Procedure Act (Chapter 17A), which generally requires challenges to agency actions to follow its exclusive review process. The plaintiffs argued that § 80F.1(13) created an independent cause of action, but the Court disagreed, distinguishing the case from Walsh v. Wahlert, where a whistleblower statute expressly referenced Chapter 17A as an alternative remedy. The Court emphasized that § 80F.1 contained “no similar language” and thus did not override Chapter 17A’s exclusivity. “The failure in § 80F.1 even to acknowledge chapter 17A’s otherwise-exclusive remedies counsels against reading § 80F.1(13) as providing a right of action against an agency outside § 17A’s requirements.”
Chandler v. Iowa Dep’t of Corr., 2025 Iowa Sup. LEXIS 16 * (Iowa 2025).