absurdity doctrine in Iowa

2017In Bearinger, we considered whether the prescription-drug defense applied 41 to administrative actions involving the revocation of drivers’ licenses. 844 N.W.2d at 105 .

2017Similarly, in Bearinger v. Iowa Department of Transportation, we considered whether a driver could invoke a prescription-drug defense 27 before an administrative tribunal seeking to revoke her driver’s license. 844 N.W.2d 104, 106 (2014).

2025Res., 897 N.W.2d 522, 534 (Iowa 2017).

2025But as the supreme court has observed, “In cases where we employ circular ambiguity, we are really applying the true absurdity doctrine, namely, overriding the text of a statute to avoid an intolerable result . . . .” Brakke, 897 N.W.2d at 538 .

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof’l Collection Consultants v. Lauron, 214 Cal. Rptr. 3d 419, 433 (Ct. App. 2017); People v. Johnson, 77 N.E.3d 615 , 619–20, (Ill. 2017); Cmty. Consol.

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof’l Collection Consultants v. Lauron, 214 Cal. Rptr. 3d 419, 433 (Ct. App. 2017); People v. Johnson, ___ N.E.3d ___, ___, 2017 WL 243396 , at *3 (Ill. 2017); Cmty. Consol.

2017In United States v. Kirby, the Supreme Court had occasion to ponder the absurdity doctrine. 74 U.S. 482, 486 (1868).

2017In United States v. Kirby, the Supreme Court had occasion to ponder the absurdity doctrine. 74 U.S. 482, 486 (1868).

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017The Supreme Court revisited the absurdity doctrine in Public Citizen v. United States Department of Justice, 491 U.S. 440 , 109 S. Ct. 2558 (1989).

2017The Supreme Court revisited the absurdity doctrine in Public Citizen v. United States Department of Justice, 491 U.S. 440 , 109 S. Ct. 2558 (1989).

2017A more straightforward description of the absurdity doctrine was presented in Case v. Olsen, where we declared, The court should give effect to the spirit of the law rather than the letter, especially so where adherence to the letter would result in absurdity, or injustice, or would lead to contradiction, or would defeat the plain purpose of the act, or where the provision was inserted through inadvertence. 234 Iowa 869, 873 , 14 N.W.2d 717, 719 (1944).

2017A more straightforward description of the absurdity doctrine was presented in Case v. Olsen, where we declared, The court should give effect to the spirit of the law rather than the letter, especially so where adherence to the letter would result in absurdity, or injustice, or would lead to contradiction, or would defeat the plain purpose of the act, or where the provision was inserted through inadvertence. 234 Iowa 869, 873 , 14 N.W.2d 717, 719 (1944).

2017See Mall Real Estate, L.L.C. v. City of Hamburg, 818 N.W.2d 190, 199 (Iowa 2012).

2017See Mall Real Estate, L.L.C. v. City of Hamburg, 818 N.W.2d 190, 199 (Iowa 2012).

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Maddox v. State, 923 So. 2d 442, 445, 448 (Fla. 2006) (holding statute prohibiting introduction of traffic citations “in any trial” limited to any trial dealing directly with the traffic offense); Commonwealth v. Wallace, 730 N.E.2d 275, 278 (Mass. 2000) (interpreting the phrase “trial on the merits” to include a default judgment); State v. Spencer, 173 S.E.2d 765, 774 (N.C. 1970) (finding “standing” in the street obstructing traffic includes walking in the street); In re Falstaff Brewing Co. re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I. 1994) (holding statute authorizing

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof’l Collection Consultants v. Lauron, 214 Cal. Rptr. 3d 419, 433 (Ct. App. 2017); People v. Johnson, 77 N.E.3d 615 , 619–20, (Ill. 2017); Cmty. Consol.

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof’l Collection Consultants v. Lauron, 214 Cal. Rptr. 3d 419, 433 (Ct. App. 2017); People v. Johnson, ___ N.E.3d ___, ___, 2017 WL 243396 , at *3 (Ill. 2017); Cmty. Consol.

2017For instance, in State v. Hoyman, we invoked the absurdity doctrine to narrow the scope of a statute that criminalized fraudulent practices in the context of public records. 863 N.W.2d 1, 14 (Iowa 2015).

2017For instance, in State v. Hoyman, we invoked the absurdity doctrine to narrow the scope of a statute that criminalized fraudulent practices in the context of public records. 863 N.W.2d 1, 14 (Iowa 2015).

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof’l Collection Consultants v. Lauron, 214 Cal. Rptr. 3d 419, 433 (Ct. App. 2017); People v. Johnson, 77 N.E.3d 615 , 619–20, (Ill. 2017); Cmty. Consol.

2017See, e.g., Brock v. Townsell, 309 S.W.3d 179, 186 (Ark. 2009); Prof'l Collection Consultants v. Lauron, 8 Cal.App.5th 958 , 214 Cal.Rptr.3d 419, 433 (2017); People v. Johnson, 77 N.E.3d 615, 619-20 (Ill. 2017); Cmty. Consol.

2017Finally, although not labeled as the absurdity doctrine, the Supreme Court applied concepts similar to it in King v. Burwell, 576 U.S. ___ , 135 S. Ct. 2480 (2015).

2017Finally, although not labeled as the absurdity doctrine, the Supreme Court applied concepts similar to it in King v. Burwell, 576 U.S. ___ , 135 S. Ct. 2480 (2015).

2025“If more than one statute relating to the subject matter at issue is relevant to the inquiry, we consider all the statutes together in an effort to harmonize them.” In re Det. of Geltz, 840 N.W.2d 273, 275 (Iowa 2013) (citation omitted); see also Iowa Code § 4.7 (requiring conflicting statutes to “be construed, if possible, so that effect is given to both”); Kelly v. State, 525 N.W.2d 409, 411 (Iowa 1994) (“[I]f two statutes conflict, courts must attempt to harmonize them in an effort to carry out the meaning and purpose of both statutes.”).

2025Here, however, we do not find that a literal construction of section 20.34 “would produce an absurd and unjust result and the literal construction in the particular action is clearly inconsistent with the purposes and policies of the act.” Id. at 540 (quoting The Sherwin-Williams Co. v. Iowa Dep’t of Revenue, 789 N.W.2d 417, 427 (Iowa 2010)); cf. In re Guardianship of Norelius, No. 18-1273, 2020 WL 402048 , at *3 (Iowa Ct. App. Jan. 23, 2020) (rejecting the appellants’ requested “reading of the statute [to] allow for taxing all attorney fees against the ward or estate, regardless of whether th

2025“If more than one statute relating to the subject matter at issue is relevant to the inquiry, we consider all the statutes together in an effort to harmonize them.” In re Det. of Geltz, 840 N.W.2d 273, 275 (Iowa 2013) (citation omitted); see also Iowa Code § 4.7 (requiring conflicting statutes to “be construed, if possible, so that effect is given to both”); Kelly v. State, 525 N.W.2d 409, 411 (Iowa 1994) (“[I]f two statutes conflict, courts must attempt to harmonize them in an effort to carry out the meaning and purpose of both statutes.”).

1872See opinion of Mr. Justice Cole in Newcomb v. Dewey, 27 Iowa, 381, 388 , and cases cited.