Iowa Code » Chapter 22 — EXAMINATION OF PUBLIC RECORDS
Iowa Code

Iowa Code § 22.5 (2026)

Enforcement of rights

✓ current as of July 2026
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The provisions of this chapter and all rights of persons under this chapter may be enforced by mandamus or injunction, whether or not any other remedy is also available. In the alternative, rights under this chapter also may be enforced by an action for judicial review according to the provisions of the Iowa administrative procedure Act, chapter 17A, if the records involved are records of an “agency” as defined in that Act. [C71, 73, 75, 77, 79, 81, §68A.5] 84 Acts, ch 1185, §4 C85, §22.5 2003 Acts, ch 44, §114 Referred to in §8A.341

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Notes of Decisions
Cited in 11 cases, 1987–2020 · leading case: Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996).
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Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996). · cites it 6× “” Iowa Code § 22.5 ; Marcus, 538 N.W.2d at 289 .”
Marcus v. Young, 538 N.W.2d 285 (Iowa 1995). · cites it 3× “§ 22.5. The Act then provides knowing or attempted violations of rights under the Act result in a simple misdemeanor.”
Iowa Film Prod. Servs. Mississippi Films, Inc. Polynation Pictures, Inc. Field of Screams, LLC Underground Films, Inc. Ticket Out Prods. Tricoast Iowa Prods., LLC Gpx Dev., LLC September Prods. LLC Lucky Mp, LLC & Recess Film Prod., LLC v. Iowa Dep't of Econ. Dev., 818 N.W.2d 207 (Iowa 2012). · cites it 5× “Section 22.5 confers a general right to injunctive relief.”
Gannon v. Bd. of Regents, 692 N.W.2d 31 (Iowa 2005). · cites it 3× “2d 382, 384 (Iowa 1989); see also Iowa Code §§ 22.5 , .10, 661.3. Because this matter is before us on an appeal from an entry of summary judgment, however, de novo review is not permitted.”
City of Riverdale, Iowa v. Allen Diercks, Marie Randol, & Tammie Picton, 806 N.W.2d 643 (Iowa 2011). · cites it 2× “” (internal quotation marks omitted)); see also Iowa Code § 22.5 (“The provisions of this chapter and all rights of persons under this chapter may be enforced by mandamus or injunction, whether or not any other remedy is also available.”
Upon the Petition of Kent D. Langholz, 887 N.W.2d 770 (Iowa 2016). · cites it 2× “While the district court sealed the documents under section 22.8, the documents also fell under one of the section 22.”
KMEG Television, Inc. v. Iowa State Bd. of Regents, 440 N.W.2d 382 (Iowa 1989). · cites it 2× “are not public records” and chapter 22 has no application. It is from this order that KMEG now appeals.”
AFSCME/Iowa Council 61 v. Iowa Dep't of Pub. Saf., 434 N.W.2d 401 (Iowa 1988). · cites it 2× “The response of the DPS, the acknowledged custodian of the lab reports at issue, was also that the records requested were confidential investigative records.”
Bruner v. Varley, 411 N.W.2d 150 (Iowa 1987). · cites it 3× “Their disagreement stems from the respondents’ assertion that an action seeking disclosure of an agency’s record should proceed in accordance with the judicial review procedures of chapter 17A.”
Amended February 10, 2017 Upon the Petition of Kent D. Langholz (Iowa 2016). · cites it 2× “7 exception applied, we declined to answer the question and instead held that the district court could issue the injunction under section 22.5, the section giving force to the exceptions found in section 22.”
Mark Leonard Milligan v. Ottumwa Police Dep't & City of Otumwa, Iowa (Iowa 2020). “On September 12, Milligan filed in the Wapello County District Court a petition in equity and request for an order of mandamus pursuant to Iowa Code sections 22.5 and 22.10. He asserted that the City and its police department violated chapter 22 by withholding the information…”
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