A few years ago the Iowa Courts adopted procedures for electronic filing in all district court matters. Recently the Iowa Supreme Court has addressed issues regarding the timeliness of filings. On Friday November 18, 2016 the Court decided the case Jacobs v. Iowa Department of Transportation, Motor Vehicle Division, No 16-0133. The issue the Court was presented with was under what circumstances for meeting a deadline a filing may relate back to the original date it was received by the EDMS system.
The relevant facts are, Jacobs counsel filed their civil administrative appeal within the required 30 days. The Clerk returned the filing due to perceived deficiencies in the civil cover sheet. This notification was sent the following day. Within an hour the corrections were made and the same Petition was re-filed. However now it was one day past the jurisdictional deadline.
The agency filed a motion to dismiss claiming the matter must be dismissed as untimely filed. Jacobs resisted and the Court dismissed the appeal. Jacobs appealed and the Iowa Supreme Court retained the case.
The Court, in an opinion by Justice Mansfield, held the corrected filing related back to the original filing and was therefore timely filed. The Iowa Court reasoned, “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.
In reaching their conclusion the Court reviewed several EDMS rules and distinguished this from the case Concerned Citizens of Southeast Polk School District v. City Development Board of State, 872 N.W.2d 399 (Iowa 2015).
Both cases are important reading for Iowa lawyers.