mootness doctrine in Iowa

2025This is known as the doctrine of mootness.” (quoting Homan v. Branstad, 864 N.W.2d 321, 328 (Iowa 2015))).

2024This is known as the doctrine of mootness.” Homan v. Branstad, 864 N.W.2d 321, 328 (Iowa 2015).

2025An exception to the mootness doctrine “provides that an appeal is not moot if a judgment left standing will cause the appellant to suffer continuing adverse collateral consequences.” In re B.B., 826 N.W.2d 425, 429 (Iowa 2013).

2025An exception to the mootness doctrine “provides that an appeal is not moot if a judgment left standing will cause the appellant to suffer continuing adverse collateral consequences.” In re B.B., 826 N.W.2d 425, 429 (Iowa 2013).

2022Rhiner v. State, 703 N.W.2d 174 , 176–77 (Iowa 2005).

2019We recognize there is an exception to the mootness doctrine for issues that are “capable of repetition but evading review.” Rhiner, 703 N.W.2d at 177 .

2020Godfrey v. State, 752 N.W.2d 413 , 419–20 (Iowa 2008) (stating willingness to consider a public interest exception to standing requirements, generally); Rush v. Ray, 332 N.W.2d 325, 326 (Iowa 1983) (finding a public interest exception to the mootness doctrine).

1985They assert, nonetheless, that the controversy meets the “public interest” exception to the mootness doctrine, citing Rush v. Ray, 332 N.W.2d 325, 326-27 (Iowa 1983).

2016See In re B.B., 826 N.W.2d 425, 428-29 (Iowa 2013) (“[O]ne exception [to the mootness doctrine] permits appellate review of otherwise moot issues when the issue is one of broad public importance likely to recur.”); State v. Hernandez- Lopez, 639 N.W.2d 226, 234 (Iowa 2002) (considering factors for deciding whether to review a moot claim).

2015In addition, the court may also order imprisonment not to exceed one year.” Iowa Code § 903.1 (1)(b) (emphasis added). 6 Even if we considered Moore’s issues moot, we could proceed to the merits because there is an exception to the mootness doctrine for “issues of broad public importance likely to recur.” Hernandez-Lopez, 639 N.W.2d at 234 .

2021Application of the exception is appropriate “where matters of public importance are presented and the problem is likely to recur.” Homan v. Branstad, 864 N.W.2d 321, 330 (Iowa 2015) (quoting In re Guardianship of Kennedy, 845 N.W.2d 707, 711 (Iowa 2014)).

2015See In re Guardianship of Kennedy, 845 N.W.2d 707, 711 (Iowa 2014) (articulating the four-part test courts use to determine whether to apply the exception to the mootness doctrine: “(1) the private or public nature of the issue; (2) the desirability of an authoritative adjudication to guide public officials in their future conduct; (3) the likelihood of the recurrence of the issue; and (4) the likelihood the issue will recur yet evade appellate review”).

2021Under 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).

2021“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).

2019On appeal, Jackson relies on In re M.T., 625 N.W.2d 702, 704 (Iowa 2001), to suggest his claim falls within an exception to the mootness doctrine.

2014An exception to the general rule exists “ “where matters of public importance are presented and the problem is likely to recur.’ ” In re M.T., 625 N.W.2d at 704 (quoting Iowa Freedom of Info.

2015City of Des Moines, 275 N.W.2d at 759 (concluding the mootness doctrine should not preclude judicial review of a declaratory order proceeding due to the important questions at issue).

2015City of Des Moines, 275 N.W.2d at 759 (concluding the mootness doctrine should not preclude judicial review of a declaratory order proceeding due to the important questions at issue).

2015“A case is moot if it no longer presents a justiciable controversy because the issues involved are academic or nonexistent.” Iowa Bankers Ass’n v. Iowa Credit Union Dep’t, 335 N.W.2d 439, 442 (Iowa 1983).

2015“A case is moot if it no longer presents a justiciable controversy because the issues involved are academic or nonexistent.” Iowa Bankers Ass’n v. Iowa Credit Union Dep’t, 335 N.W.2d 439, 442 (Iowa 1983).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot....” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky.Ct.App. 1955); accord In re Storar, 52 N.Y.2d 363 , 438 N.Y.S.2d 266 , 420 N.E.2d 64 , 66-67 n. 1 (1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), super seded by statute on other grounds as noted in In re M.B., 6 N.Y.3d 437 , 813 N.Y.S.2d 349 , 846 N.E.2d 794, 796 (2006).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot . . . .” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky. Ct. App. 1955); accord In re Storar, 420 N.E.2d 64 , 66–67 n.1 (N.Y. 1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), superseded by statute on 9 other grounds as noted in In re M.B., 846 N.E.2d 794, 796 (N.Y. 2006).

2009Courts in other states have observed that survival statutes providing that causes of action or suits do not abate upon the death of a party do not dispense “with the requirement that there be an actual existing controversy between the litigants.” Olson v. Comm’n for Lawyer Discipline, 901 S.W.2d 520, 523 (Tex.App.1995); accord In re L.W., 168 Ohio App.3d 613 , 861 N.E.2d 546, 551 (Ct.App. 2006) (holding survival statute did not operate to except suits from the mootness doctrine).

2009Courts in other states have observed that survival statutes providing that causes of action or suits do not abate upon the death of a party do not dispense “with the requirement that there be an actual existing controversy between the litigants.” Olson v. Comm’n for Lawyer Discipline, 901 S.W.2d 520, 523 (Tex. App. 1995); accord In re L.W., 861 N.E.2d 546, 551 (Ohio Ct. App. 2006) (holding survival statute did not operate to except suits from the mootness doctrine).

2009Courts in other states have observed that survival statutes providing that causes of action or suits do not abate upon the death of a party do not dispense “with the requirement that there be an actual existing controversy between the litigants.” Olson v. Comm’n for Lawyer Discipline, 901 S.W.2d 520, 523 (Tex.App.1995); accord In re L.W., 168 Ohio App.3d 613 , 861 N.E.2d 546, 551 (Ct.App. 2006) (holding survival statute did not operate to except suits from the mootness doctrine).

2009Courts in other states have observed that survival statutes providing that causes of action or suits do not abate upon the death of a party do not dispense “with the requirement that there be an actual existing controversy between the litigants.” Olson v. Comm’n for Lawyer Discipline, 901 S.W.2d 520, 523 (Tex. App. 1995); accord In re L.W., 861 N.E.2d 546, 551 (Ohio Ct. App. 2006) (holding survival statute did not operate to except suits from the mootness doctrine).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot....” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky.Ct.App. 1955); accord In re Storar, 52 N.Y.2d 363 , 438 N.Y.S.2d 266 , 420 N.E.2d 64 , 66-67 n. 1 (1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), super seded by statute on other grounds as noted in In re M.B., 6 N.Y.3d 437 , 813 N.Y.S.2d 349 , 846 N.E.2d 794, 796 (2006).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot . . . .” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky. Ct. App. 1955); accord In re Storar, 420 N.E.2d 64 , 66–67 n.1 (N.Y. 1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), superseded by statute on 9 other grounds as noted in In re M.B., 846 N.E.2d 794, 796 (N.Y. 2006).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot....” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky.Ct.App. 1955); accord In re Storar, 52 N.Y.2d 363 , 438 N.Y.S.2d 266 , 420 N.E.2d 64 , 66-67 n. 1 (1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), super seded by statute on other grounds as noted in In re M.B., 6 N.Y.3d 437 , 813 N.Y.S.2d 349 , 846 N.E.2d 794, 796 (2006).

2009As one court has observed, “The real point is not abatement of the appeal but whether the question has become moot . . . .” Mason v. Commonwealth, 283 S.W.2d 845, 846 (Ky. Ct. App. 1955); accord In re Storar, 420 N.E.2d 64 , 66–67 n.1 (N.Y. 1981) (noting existence of survival statutes, yet holding issue posed by death of the ward was “properly resolved by consideration of the principles applicable to moot controversies”), superseded by statute on 9 other grounds as noted in In re M.B., 846 N.E.2d 794, 796 (N.Y. 2006).

2008A second aspect of the mootness doctrine is known as the “personal stake requirement.” U.S. Parole Comm’n v. Geraghty, 445 U.S. 388, 396 , 100 S. Ct. 1202, 1208 , 63 L.

2008A second aspect of the mootness doctrine is known as the “personal stake requirement.” U.S. Parole Comm’n v. Geraghty, 445 U.S. 388, 396 , 100 S. Ct. 1202, 1208 , 63 L.

2005Council v. Wifvat, 328 N.W.2d 920, 922 (Iowa 1983).

2005Council v. Wifvat, 328 N.W.2d 920, 922 (Iowa 1983).

2018The Clarke County court contrasted Lewis Investments., Inc. v. City of Iowa City, 703 N.W.2d 180 , 183–84 (Iowa 2005), where the court rejected a mootness challenge while noting, although the city of Iowa City had deposited the condemnation award, the city had not yet sold the property to a third party so the court could still restore the parties to their former positions, with Welton v. Iowa State Highway Commission, 227 N.W. 332, 333 (Iowa 1929), where the court dismissed the appeal as moot while noting the 8 orchard had been “taken for highway purposes and the paving laid.” 862 N.W.2d at 17

2015In Lewis Investments, Inc. v. City of Iowa City, we rejected a mootness challenge raised on appeal in a condemnation action. 703 N.W.2d 180 , 183–84 (Iowa 2005).

2008Buechel v. Five Star Quality Care, Inc., 745 N.W.2d 732, 735-36 (Iowa 2008). 3 .

2008Buechel v. Five Star Quality Care, Inc., 745 N.W.2d 732 , 735– 36 (Iowa 2008). 6 compensation commissioner during judicial review.

2022Bit Labs, Inc. v. Baker, 11 F.4th 3, 10 (1st Cir. 2021) (alteration in original) (quoting Town of Portsmouth v. Lewis, 813 F.3d 54, 59 (1st Cir. 2016)).

2022Bit Labs, Inc. v. Baker, 11 F.4th 3, 10 (1st Cir. 2021) (alteration in original) (quoting Town of Portsmouth v. Lewis, 813 F.3d 54, 59 (1st Cir. 2016)).

2021To determine whether an appeal is moot, we consider “whether a judgment, if rendered, would have any practical legal effect upon the existing controversy.” Junkins v. Branstad, 421 N.W.2d 130, 133 (Iowa 1988).