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Sharply divided Iowa Supreme Court dismisses wrongful imprisonment claim
Dissenting justices call majority’s decision ‘frightening’ and ‘profoundly wrong’
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A sharply divided Iowa Supreme Court has affirmed a lower court’s decision dismissing a former prisoner’s claim for damages due to wrongful imprisonment.
In strongly worded dissenting opinions, two of the Iowa justices called the majority’s decision in the case on Friday “frightening” and “profoundly wrong,” warning that it could remove any disincentive for state officials to willfully hold prisoners well beyond their scheduled release dates.
Justice David May, joined by Chief Justice Susan Christensen and Justices Thomas Waterman and Edward Mansfield, upheld a district court judge’s decision to dismiss Eugene Sikora’s claim for damages for being held in prison past his proper release date.
Justice Christopher McDonald, joined by Justices Dana Oxley and Matthew McDermott, filed a dissenting opinion. In addition, Oxley filed a dissenting opinion of her own, in which she was joined by McDonald and McDermott, and McDermott authored a dissenting opinion of his own, in which he was joined by McDonald and Oxley.
In his lawsuit, Sikora claimed the state had released him from prison five months late due to a mathematical miscalculation. Three years after he was released, Sikora sued the state and the director of the Iowa Department of Corrections for wrongful imprisonment, seeking monetary damages.
A district court judge dismissed the lawsuit, citing the doctrine of sovereign immunity in which the state and its employees are generally considered immune from state-law tort claims for monetary damages arising from wrongful imprisonment.
In upholding that district court decision, Justice May, writing for the majority, stated that no exceptions to the doctrine of sovereign immunity applied to the case and concluded Sikora’s suit could not proceed.
“The district court properly rejected Sikora’s state law claims for money damages,” May wrote. “But this does not mean that our courts are unable to help persons who are wrongfully detained in Iowa prisons. If Sikora had asked our courts for non-monetary relief — like an order to release him from prison — sovereign immunity would not have foreclosed his request.”
May noted there are “pathways for wrongfully convicted prisoners to obtain money damages in state court. One element of Iowa law, he noted, waives sovereign immunity to permit money damages claims by people who are imprisoned because of wrongful convictions — but that law doesn’t apply to Sikora’s case, May wrote, because he pleaded guilty to his crimes.
McDonald says majority is ‘profoundly wrong’
In his dissenting opinion, Justice McDonald noted that America’s foundational principles and common law enabled people injured by government officials to sue those same government officials for monetary damages and other relief.
“This common law regime of rights was codified as fundamental law in the structure and text of the federal and state constitutions, including the Iowa Constitution,” McDonald wrote. “The state now claims that its officials can violate this fundamental law and imprison people with impunity … Not even King George III asserted such power for his officials, and our forefathers attempted to make sure none could assert it here. They understood that tyranny authorized by statute is still tyranny.”
McDonald wrote that the law extending the state’s immunity in cases such as Sikora’s “is illegal and void because the extension of sovereign immunity to these government officials contravenes the structure and text of the state constitution.”
McDonald also characterized the majority’s decision as “profoundly wrong” and an example of “willful ignorance” with regard to its refusal to acknowledge past court decisions. The “special status” the majority conferred upon state officials, McDonald wrote, “does not make sense. What logical distinction would provide state officials immunity superior to federal and local officials?”
Even if the state had “some legitimate interest in limiting the liability of its employees” for their conduct, McDonald added, “its chosen means in this case — the total elimination of any right of recovery for wrongfully imprisoned people — is unduly oppressive and thus constitutionally forbidden.”
McDonald said the state’s claim of sovereign immunity was “nothing more than an assertion that the government and its officials have the unilateral right to alter the state constitution through normal legislation and wrongly imprison people without being held to account. That assertion is odious and repugnant to republican constitutional order.”
Noting that the Iowa state flag says, “Our liberties we prize and our rights we will maintain,” McDonald opined that the court’s majority was rejecting “the very core of liberty at the heart of our state constitutional order” by asserting that wrongful imprisonment at the hands of state officials is lawful. “It should not be celebrated here,” he wrote. “It is absolutism, pure, simple, and naked.”
In his separate dissenting opinion, Justice McDermott called the majority’s decision “both frightening and, as a legal matter, wrong.”
McDermott said “the evidence is overwhelming that during Iowa’s founding era, people could pursue lawsuits for money damages against government officials in both Iowa and federal courts. The majority’s claim to the contrary — that sovereign immunity protects state officials from private causes of action — is fundamentally incompatible with the historical evidence.”
McDermott added that the majority’s dismissal of Sikora’s claim left Sikora “without a remedy despite his having allegedly suffered five months of unlawful confinement. And after today, it is hard to see what disincentive any state prison official would have to unlawfully hold an inmate well beyond his release date.”
This article first appeared in the Iowa Capital Dispatch.
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