Iowa Code

Iowa Code § 17A.15 (2026)

Final decisions — proposed decisions — conclusiveness — review by the agency

✓ current as of July 2026

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1. When the agency presides at the reception of the evidence in a contested case, the decision of the agency is a final decision. 2. When the agency did not preside at the reception of the evidence in a contested case, the presiding officer shall make a proposed decision. Findings of fact shall be prepared by the officer presiding at the reception of the evidence in a contested case unless the officer becomes unavailable to the agency. If the officer is unavailable, the findings of fact may be\n\nTue Dec 09 22:32:44 2025 Iowa Code 2026, Chapter 17A (50, 1) §17A.15, IOWA ADMINISTRATIVE PROCEDURE ACT 20\n\nprepared by another person qualified to be a presiding officer who has read the record, unless demeanor of witnesses is a substantial factor. If demeanor is a substantial factor and the presiding officer is unavailable, the portions of the hearing involving demeanor shall be heard again or the case shall be dismissed. 3. When the presiding officer makes a proposed decision, that decision then becomes the final decision of the agency without further proceedings unless there is an appeal to, or review on motion of, the agency within the time provided by rule. On appeal from or review of the proposed decision, the agency has all the power which it would have in initially making the final decision except as it may limit the issues on notice to the parties or by rule. The agency may reverse or modify any finding of fact if a preponderance of the evidence will support a determination to reverse or modify such a finding, or may reverse or modify any conclusion of law that the agency finds to be in error. In cases where there is an appeal from a proposed decision or where a proposed decision is reviewed on motion of the agency, an opportunity shall be afforded to each party to file exceptions, present briefs and, with the consent of the agency, present oral arguments to the agency members who are to render the final decision. 4. This section shall not preclude an agency from instituting a system whereby the proposed decision of a presiding officer in a contested case may be appealed to, or reviewed on motion of, a body consisting of one or more persons that is between the presiding officer and the agency. If an agency institutes such a system of intermediate review, the proposed decision of the presiding officer becomes the final decision of the agency without further proceedings unless there is an appeal to, or review on motion of, the intermediate reviewing body within the time provided by rule. An intermediate reviewing body may be vested with all or a part of the power which it would have in initially making the decision. A decision of such an intermediate reviewing body is also a proposed decision and shall become the final decision of the agency without further proceedings unless there is an appeal to, or review on motion of, the agency within the time provided by rule. In cases where there is an appeal from a proposed decision rendered by a presiding officer to an intermediate reviewing body, or where such a proposed decision is reviewed on motion of an intermediate reviewing body, an opportunity shall be afforded to each party to file exceptions, present briefs and, with the consent of the intermediate reviewing body, present oral arguments to those who are to render the decision. 5. When an appeal from an agency decision in a contested case may be taken to another agency pursuant to statute, or a second agency may according to statute review on its own motion the decision in a contested case by the first agency, the appeal or review shall be deemed a continuous proceeding as though before one agency. A decision of the first agency in such a case is a proposed decision and shall become the final decision without further proceedings unless there is an appeal to, or review on motion of, the second agency within the time provided by statute or rule. In deciding an appeal from or review of a proposed decision of the first agency, the second agency shall have all those powers conferred upon it by statute and shall afford each party an opportunity to file exceptions, present briefs and, with its consent, present oral arguments to agency members who are to render the final decision. [C75, 77, 79, 81, §17A.15] 98 Acts, ch 1202, §17, 46 Referred to in §10A.321, 10A.330, 10A.801, 17A.9, 256.7, 331.190, 421.17

Notes of Decisions

Cited in 48 cases (1 in the last 5 years), 1978–2022 · leading case: Aluminum Co. of Am. v. Musal, 622 N.W.2d 476 (Iowa 2001).

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Aluminum Co. of Am. v. Musal, 622 N.W.2d 476 (Iowa 2001). · cites it 12× “See Iowa Code § 17A.15(3) (1999) (commissioner permitted to limit issues to be reviewed by notice or rule).”

Marovec v. Pmx Indus., 693 N.W.2d 779 (Iowa 2005). · cites it 8× “29; see also Iowa Code § 17A.15(3) ("On appeal from or review of the proposed decision, the agency has all the power which it would have in initially making the final decision except as it may limit the issues on notice to the parties or by rule.”

Cont'l Tel. Co. v. Colton, 348 N.W.2d 623 (Iowa 1984). · cites it 12× “The district court in the present case interpreted our decision in LeaseAmerica as holding that unless an intra-agency appeal is required by statute, a party may seek judicial review of the decision of the presiding officer at a contested case hearing if that decision has become…”

Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Comm'n, 394 N.W.2d 375 (Iowa 1986). · cites it 4× “Iowa Code §§ 17A.15(2), (3); 601A.15(7). The Union filed a petition for judicial review of this decision in district court.”

Hy-Vee Food Stores, Inc. v. Iowa Civil Rights Comm'n, 453 N.W.2d 512 (Iowa 1990). · cites it 4× “See Iowa Code §§ 17A.15(2), (3); 601A.15(8)(a)(7).”

Trade Professionals, Inc. v. Shriver, 661 N.W.2d 119 (Iowa 2003). · cites it 6× “24(2) states: “In addition to the provisions of section 17A.15, the workers’ compensation commissioner may affirm, modify, or reverse the decision of a deputy commissioner or the commissioner may remand the decision to the deputy commissioner for further proceedings.”

Leaseamerica Corp. v. Iowa Dep't of Revenue, 333 N.W.2d 847 (Iowa 1983). · cites it 12× “Neither section 17A.15 nor section 17A.19(1) “expressly” requires an intra-agency appeal.”

Iowa State Fairgrounds Sec. v. Iowa Civil Rights Comm'n, 322 N.W.2d 293 (Iowa 1982). · cites it 3× “” § 17A.15(3). When reviewing a proposed decision, “the agency has all the power it would have in initially making the final decision except as it may limit the issues on notice to the parties or by rule.”

Jackson Cnty. Pub. Hosp. v. Pub. Emp. Relations Bd., 280 N.W.2d 426 (Iowa 1979). · cites it 2× “See § 17A.15(3). The district court was to review and consider the consequences of the PERB's finding of "joint employment.”

City of Des Moines v. Iowa Dep't of Transp. & Iowa Transp. Comm'n, 911 N.W.2d 431 (Iowa 2018). · cites it 2× “There, the statute provided, "In addition to the provisions of section 17A.15, the industrial commissioner, on appeal, may limit the presentation of evidence as provided by rule.”

Ramsey v. Iowa Dep't of Transp., Motor Veh. Div., 576 N.W.2d 103 (Iowa 1998). · cites it 12× “The DOT argues that the appeal rights are controlled by the provisions of the Administrative Procedure Act, Iowa Code section 17A.15. That section provides: 1.”

McSpadden v. Big Ben Coal Co., 288 N.W.2d 181 (Iowa 1980). · cites it 2× “The first two, §§ 17A.15 (2), .16(1), The Code, refer to the specificity required of proposed or final decisions of an agency, not that of its rulings on motions.”

Show all 48 citing cases →

— Iowa Code § 17A.15(1) — 1 case

Petro v. Davenport Civil Rights Comm'n (Iowa Ct. App. 2022).

— Iowa Code § 17A.15(2) — 11 cases

Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Comm'n, 394 N.W.2d 375 (Iowa 1986). “Iowa Code §§ 17A.15(2), (3); 601A.15(7). The Union filed a petition for judicial review of this decision in district court.”

Hy-Vee Food Stores, Inc. v. Iowa Civil Rights Comm'n, 453 N.W.2d 512 (Iowa 1990). “See Iowa Code §§ 17A.15(2), (3); 601A.15(8)(a)(7).”

Cont'l Tel. Co. v. Colton, 348 N.W.2d 623 (Iowa 1984). “The district court in the present case interpreted our decision in LeaseAmerica as holding that unless an intra-agency appeal is required by statute, a party may seek judicial review of the decision of the presiding officer at a contested case hearing if that decision has become…”

City of Davenport v. Newcomb, 820 N.W.2d 882 (Iowa Ct. App. 2012).

Trade Professionals, Inc. v. Shriver, 661 N.W.2d 119 (Iowa 2003). “24(2) states: “In addition to the provisions of section 17A.15, the workers’ compensation commissioner may affirm, modify, or reverse the decision of a deputy commissioner or the commissioner may remand the decision to the deputy commissioner for further proceedings.”

— Iowa Code § 17A.15(3) — 32 cases

Aluminum Co. of Am. v. Musal, 622 N.W.2d 476 (Iowa 2001). “See Iowa Code § 17A.15(3) (1999) (commissioner permitted to limit issues to be reviewed by notice or rule).”

Marovec v. Pmx Indus., 693 N.W.2d 779 (Iowa 2005). “29; see also Iowa Code § 17A.15(3) ("On appeal from or review of the proposed decision, the agency has all the power which it would have in initially making the final decision except as it may limit the issues on notice to the parties or by rule.”

Iowa State Fairgrounds Sec. v. Iowa Civil Rights Comm'n, 322 N.W.2d 293 (Iowa 1982). “” § 17A.15(3). When reviewing a proposed decision, “the agency has all the power it would have in initially making the final decision except as it may limit the issues on notice to the parties or by rule.”

Jackson Cnty. Pub. Hosp. v. Pub. Emp. Relations Bd., 280 N.W.2d 426 (Iowa 1979). “See § 17A.15(3). The district court was to review and consider the consequences of the PERB's finding of "joint employment.”

— Iowa Code § 17A.15(4) — 1 case

Frank v. Iowa Dep't of Transp., Motor Veh. Div., 386 N.W.2d 86 (Iowa 1986).

— Iowa Code § 17A.15(5) — 1 case

CMC Real Est. Corp. v. Iowa Dep't of Transp., Rail & Water Div., 475 N.W.2d 166 (Iowa 1991).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.