Martin-Trigona v. Baxter, 435 N.W.2d 744 (Iowa 1989). · Go Syfert
Martin-Trigona v. Baxter, 435 N.W.2d 744 (Iowa 1989). Cases Citing This Book View Copy Cite
“a moot case is one that no longer presents a justiciable controversy because the issues involved have become academic or nonexistent. the test is whether a judgment, if rendered, would have any practical legal effect upon the existing controversy.”
9 citation events (8 in the last 25 years) across 2 distinct courts.
Top citers, strongest first. 7 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) City of Bettendorf v. Moritz
Iowa Ct. App. · 2011 · signal: see · quote attribution · 1 verbatim quote · confidence high
a moot case is one that no longer presents a justiciable controversy because the issues involved have become academic or nonexistent. the test is whether a judgment, if rendered, would have any practical legal effect upon the existing controversy.
discussed Cited as authority (rule) In the Matter of the Conservatorship of Justin Paul Sulzner (2×) also: Cited "see"
Iowa Ct. App. · 2021 · confidence medium
Under the mootness doctrine, we refrain from deciding a case “that no longer presents a justiciable controversy because the issues involved have become academic or nonexistent.” Martin-Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989).
discussed Cited as authority (rule) Jose Lopez v. State of Iowa
Iowa Ct. App. · 2021 · confidence medium
“A moot case is one that no longer presents a justiciable controversy because the issues involved have become academic or nonexistent.” Martin- Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989). “[C]ourts do not decide cases when the underlying controversy is moot.” Rhiner v. State, 703 N.W.2d 174, 176 (Iowa 2005).
cited Cited as authority (rule) Kerby v. Jerry Kerby Revocable Trust
Iowa Ct. App. · 2017 · confidence medium
A case is moot if it “no longer presents a justiciable controversy because the issues involved have become academic or nonexistent.” Martin-Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989).
discussed Cited "see" Riley Drive Entertainment I, Inc. d/b/a Tonic Bar v. Governor Kimberly K. Reynolds, in Her Official Capacity as governor of the State of Iowa and Iowa Department of Public Health
Iowa · 2022 · signal: see · confidence high
See Martin-Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989) (declining to apply the public-importance exception to a challenge to certain procedures at the Democratic presidential caucus, noting that “[t]he Iowa Democratic Party might well decide to change its caucus procedures, as it is certainly free to do, before the next presidential election”).
cited Cited "see" Leaf v. Iowa Methodist Medical Center
Iowa Ct. App. · 1990 · signal: see · confidence high
See Martin-Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989); Department *894 of General Services, State of Iowa v. R.M.
discussed Cited "see, e.g." Shawn Shelton v. The Trust Created by the Joint Trust Agreement of Larry E. Shelton and Katherine Shelton, Mary Joleen Pavelka, Jan Marie Gwinn, and Ann Jetora Mueller f/k/a Jetora Ann Mueller
Iowa Ct. App. · 2021 · signal: see, e.g. · confidence medium
See, e.g., Martin-Trigona v. Baxter, 435 N.W.2d 744, 745 (Iowa 1989) (explaining case is moot when it “no longer presents a justiciable controversy because the issues involved have become academic or nonexistent”).
Retrieving the full opinion text from the archive…
Anthony R. MARTIN-TRIGONA, Appellant,
v.
Elaine BAXTER, Iowa Secretary of State, and the Iowa Democratic Party, Appellees
88-08.
Supreme Court of Iowa.
Feb 22, 1989.
435 N.W.2d 744
Anthony R. Martin-Trigona, Middletown, Conn., pro se., Thomas J. Miller, Atty. Gen., and Julie F. Pottorff, Asst. Atty. Gen., for appellee Baxter.
McGiverin, Lavorato, Neuman, Snell, Andreasen.
Cited by 7 opinions  |  Published
LAVORATO, Justice.

Anthony R. Martin-Trigona, a former candidate for the Democratic presidential nomination, sued the Iowa Democratic Party and Elaine Baxter, who is the Iowa Secretary of State, seeking declaratory and injunctive relief regarding the conduct of the 1988 Iowa Democratic presidential caucuses. He alleged that the caucus procedures violated various state and federal statutory and constitutional provisions. The district court dismissed the case upon the appellees’ motion.

Martin-Trigona sought our review, and Baxter moved to dismiss his appeal. Among other things, Baxter asserts that the issues raised are moot because the nominating process is over. We agree with her and dismiss the appeal.

A moot case is one that no longer presents a justiciable controversy because the issues involved have become academic or nonexistent. Junkins v. Branstad, 421 N.W.2d 130, 133 (Iowa 1988). “The test is whether a judgment, if rendered, would have any practical legal effect upon the existing controversy.” Id.

As Baxter contends, resolution of Martin-Trigona’s claims would have no effect upon the existing controversy. Martin-Trigona did not challenge the caucus system generally, but only as it was being conducted in 1988, specifically. The issues Martin-Trigona raised are truly academic because nothing we could do now would affect the 1988 caucuses.

Baxter is also correct in arguing that the “public interest” exception to the mootness doctrine does not apply in this case. The criteria for whether to apply the exception are: “ ‘(1) the public or private nature of the question presented, (2) desirability of an authoritative adjudication for future guidance of public officials, and (3) likelihood of future recurrence of the same or similar problem.’ ” Rush v. Ray, 332 N.W. 2d 325, 326 (Iowa 1983).

The first two factors indicate that the exception should not be applied here. We, like the U.S. Supreme Court, think the first amendment associational interests of a political party give its nominee selection processes precedence over most “public” considerations. Cf Tashjian v. Republican Party, 479 U.S. 208, 214, 225, 107 S.Ct. 544, 548-49, 554, 93 L.Ed.2d 514, 523-24, 530 (1986) (party has first amendment associational right to define the “association;” statute limiting primary participation to party members was unconstitutional infringement of that right). The questions Martin-Trigona presents to us are therefore private, rather than public, in nature. As such, public officials have no need for our guidance here.

Further, the likelihood of the recurrence of these issues, as Baxter argues, is “purely speculative.” The Iowa Democratic Party might well decide to change its caucus procedures, as it is certainly free to do, before the next presidential election.

In Meyer v. Grant, as Martin-Trigona asserts, the Supreme Court said the passing of an election does not necessarily make an election issue moot. 486 U.S. -, - n. 2, 108 S.Ct. 1886, 1890 n. 2, 100 L.Ed.2d 425, 432 n. 2 (1988) (dictum). The factors the Court considered in making the mootness decision were whether the issue was likely to recur and whether the duration of the challenged action was long enough for complete litigation to take place. Id. Here, Martin-Trigona’s argument fails under the first factor, as explained above. He fares no better under the second factor. The caucus system has been used since 1972, a fact Martin-Trigo-na himself points out; thus, he had plenty of time to litigate a challenge to it.

[*746] In summary, we hold that Martin-Trigo-na’s appeal must be dismissed because the issues it raises are moot. The “public interest” exception does not apply here.

We also note that a cursory examination of Martin-Trigona’s substantive arguments indicates to us that they are without merit.

APPEAL DISMISSED.