Iowa Code

Iowa Code § 22.8 (2026)

Injunction to restrain examination

✓ current as of July 2026
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1. The district court may grant an injunction restraining the examination, including copying, of a specific public record or a narrowly drawn class of public records. A hearing shall be held on a request for injunction upon reasonable notice as determined by the court to persons requesting access to the record which is the subject of the request for injunction. It shall be the duty of the lawful custodian and any other person seeking an injunction to ensure compliance with the notice requirement. Such an injunction may be issued only if the petition supported by affidavit shows and if the court finds both of the following: a. That the examination would clearly not be in the public interest. b. That the examination would substantially and irreparably injure any person or persons. 2. An injunction shall be subject to the rules of civil procedure except that the court in its discretion may waive bond. 3. In actions brought under this section the district court shall take into account the policy of this chapter that free and open examination of public records is generally in the public interest even though such examination may cause inconvenience or embarrassment to public officials or others. A court may issue an injunction restraining examination of a public record or a narrowly drawn class of such records, only if the person seeking the injunction demonstrates by clear and convincing evidence that this section authorizes its issuance. An injunction restraining the examination of a narrowly drawn class of public records may be issued only if such an injunction would be justified under this section for every member within the class of records involved if each of those members were considered separately. 4. Good-faith, reasonable delay by a lawful custodian in permitting the examination and copying of a government record is not a violation of this chapter if the purpose of the delay is any of the following: a. To seek an injunction under this section. b. To determine whether the lawful custodian is entitled to seek such an injunction or should seek such an injunction. c. To determine whether the government record in question is a public record, or confidential record. d. To determine whether a confidential record should be available for inspection and copying to the person requesting the right to do so. A reasonable delay for this purpose shall not exceed twenty calendar days and ordinarily should not exceed ten business days. e. Actions for injunctions under this section may be brought by the lawful custodian of a government record, or by another government body or person who would be aggrieved or adversely affected by the examination or copying of such a record. f. The rights and remedies provided by this section are in addition to any rights and remedies provided by section 17A.19. [C71, 73, 75, 77, 79, 81, §68A.8] 84 Acts, ch 1185, §7 C85, §22.8 Referred to in §23.5, 23.11

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Notes of Decisions
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 57× “” Iowa Code § 22.8 (l)(a)-(6). The party opposing disclosure carries the burden of establishing both elements by clear and convincing evidence.”
City of Riverdale, Iowa v. Allen Diercks, Marie Randol, & Tammie Picton, 806 N.W.2d 643 (Iowa 2011). · cites it 23× “10(3)(c) requires Riverdale to pay defendants’ reasonable attorney fees because the district court found the City violated the statute by withholding the video and implicitly rejected the City’s defense of a “good-faith, reasonable delay” under section 22.8(4). The district…”
Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996). · cites it 33× “See Iowa Code § 22.8 (1). In response, Flynn contends that his rule 179(b) motion was effectually a petition for injunctive relief, even though it was not labeled as such.”
Upon the Petition of Kent D. Langholz, 887 N.W.2d 770 (Iowa 2016). · cites it 18× “Iowa Code § 22.8 (1). This injunction is an equitable remedy that is independent of the section 22.”
Horsfield Materials, Inc. v. City of Dyersville, 834 N.W.2d 444 (Iowa 2013). · cites it 13× “However, Hors-field argues that there is an implicit time limit of twenty days based on the following language in section 22.8: 4. Good-faith, reasonable delay by a lawful custodian in permitting the examination and copying of a government record is not a violation of this…”
Marcus v. Young, 538 N.W.2d 285 (Iowa 1995). · cites it 16× “Iowa Code § 22.8 (1). The section further provides actions for injunctions may be initiated by the lawful custodian of a government record, another government body, or a person adversely affected by the examination or copying.”
Mark D. Hall v. Broadlawns Med. Ctr., 811 N.W.2d 478 (Iowa 2012). · cites it 17× “Iowa Code section 22.8 allows for injunctions to prevent disclosure when the court finds both that examination is “clearly” not in the public interest and that examination would “substantially ánd irreparably injure any person or persons.”
Ne. Council on Substance Abuse, Inc. v. Iowa Dep't of Pub. Health, 513 N.W.2d 757 (Iowa 1994). · cites it 10× “See Iowa Code § 22.8 . NECSA sought to enjoin the department from releasing NECSA’s past grant applications to Covenant on the grounds that such documents are confidential.”
Am. Civil Liberties Union Found. of Iowa, Inc. v. Records Custodian, Atl. Cmty. Sch. Dist., 818 N.W.2d 231 (Iowa 2012). · cites it 8× “2d 523, 526 (Iowa 1980) (internal quotation marks omitted), superseded by statute on other grounds, Iowa Code § 22.8 , as recognized in City of Sioux City v.”
Burton v. Univ. of Iowa Hospitals & Clinics, 566 N.W.2d 182 (Iowa 1997). · cites it 8× “Whatever the reason, such deletion created a conflict where none existed before.”
DeLaMater v. Marion Civil Serv. Comm'n, 554 N.W.2d 875 (Iowa 1996). · cites it 4× “See Iowa Code § 22.8 (3) (stating the policy of chapter 22 is free and open examination of public records even though it may cause embarrassment); Celmins, 457 F.”
Johnson v. Univ. of Iowa, 408 F. Supp. 2d 728 (S.D. Iowa 2004). · cites it 5× “The purpose statement in the policy, § 22.8(a), suggests that all parents are entitled to parental leave: the stated purpose is “[t]o permit parents who have care giving responsibilities to have time off to spend with a child newly added to the family and, to the extent…”
— Iowa Code § 22.8(1) — 2 cases
Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996). “See Iowa Code § 22.8 (1). In response, Flynn contends that his rule 179(b) motion was effectually a petition for injunctive relief, even though it was not labeled as such.”
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). “” Iowa Code § 22.8 (l)(a)-(6). The party opposing disclosure carries the burden of establishing both elements by clear and convincing evidence.”
— Iowa Code § 22.8(3) — 12 cases
Ne. Council on Substance Abuse, Inc. v. Iowa Dep't of Pub. Health, 513 N.W.2d 757 (Iowa 1994). “See Iowa Code § 22.8 . NECSA sought to enjoin the department from releasing NECSA’s past grant applications to Covenant on the grounds that such documents are confidential.”
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). “” Iowa Code § 22.8 (l)(a)-(6). The party opposing disclosure carries the burden of establishing both elements by clear and convincing evidence.”
Gabrilson v. Flynn, 554 N.W.2d 267 (Iowa 1996). “See Iowa Code § 22.8 (1). In response, Flynn contends that his rule 179(b) motion was effectually a petition for injunctive relief, even though it was not labeled as such.”
Mark D. Hall v. Broadlawns Med. Ctr., 811 N.W.2d 478 (Iowa 2012). “Iowa Code section 22.8 allows for injunctions to prevent disclosure when the court finds both that examination is “clearly” not in the public interest and that examination would “substantially ánd irreparably injure any person or persons.”
— Iowa Code § 22.8(4) — 8 cases
City of Riverdale, Iowa v. Allen Diercks, Marie Randol, & Tammie Picton, 806 N.W.2d 643 (Iowa 2011). “10(3)(c) requires Riverdale to pay defendants’ reasonable attorney fees because the district court found the City violated the statute by withholding the video and implicitly rejected the City’s defense of a “good-faith, reasonable delay” under section 22.8(4). The district…”
Horsfield Materials, Inc. v. City of Dyersville, 834 N.W.2d 444 (Iowa 2013). “However, Hors-field argues that there is an implicit time limit of twenty days based on the following language in section 22.8: 4. Good-faith, reasonable delay by a lawful custodian in permitting the examination and copying of a government record is not a violation of this…”
Mark D. Hall v. Broadlawns Med. Ctr., 811 N.W.2d 478 (Iowa 2012). “Iowa Code section 22.8 allows for injunctions to prevent disclosure when the court finds both that examination is “clearly” not in the public interest and that examination would “substantially ánd irreparably injure any person or persons.”
Marcus v. Young, 538 N.W.2d 285 (Iowa 1995). “Iowa Code § 22.8 (1). The section further provides actions for injunctions may be initiated by the lawful custodian of a government record, another government body, or a person adversely affected by the examination or copying.”
City of Dubuque v. Dubuque Racing Ass'n, 420 N.W.2d 450 (Iowa 1988).
— Iowa Code § 22.8(4)(a) — 1 case
Horsfield Materials, Inc. v. City of Dyersville, 834 N.W.2d 444 (Iowa 2013). “However, Hors-field argues that there is an implicit time limit of twenty days based on the following language in section 22.8: 4. Good-faith, reasonable delay by a lawful custodian in permitting the examination and copying of a government record is not a violation of this…”
— Iowa Code § 22.8(4)(d) — 3 cases
Horsfield Materials, Inc. v. City of Dyersville, 834 N.W.2d 444 (Iowa 2013). “However, Hors-field argues that there is an implicit time limit of twenty days based on the following language in section 22.8: 4. Good-faith, reasonable delay by a lawful custodian in permitting the examination and copying of a government record is not a violation of this…”
— Iowa Code § 22.8(a) — 1 case
Johnson v. Univ. of Iowa, 408 F. Supp. 2d 728 (S.D. Iowa 2004). “The purpose statement in the policy, § 22.8(a), suggests that all parents are entitled to parental leave: the stated purpose is “[t]o permit parents who have care giving responsibilities to have time off to spend with a child newly added to the family and, to the extent…”
— Iowa Code § 22.8(b)(1)(a) — 1 case
Johnson v. Univ. of Iowa, 408 F. Supp. 2d 728 (S.D. Iowa 2004). “The purpose statement in the policy, § 22.8(a), suggests that all parents are entitled to parental leave: the stated purpose is “[t]o permit parents who have care giving responsibilities to have time off to spend with a child newly added to the family and, to the extent…”
— Iowa Code § 22.8(b)(1)(b) — 1 case
Johnson v. Univ. of Iowa, 408 F. Supp. 2d 728 (S.D. Iowa 2004). “The purpose statement in the policy, § 22.8(a), suggests that all parents are entitled to parental leave: the stated purpose is “[t]o permit parents who have care giving responsibilities to have time off to spend with a child newly added to the family and, to the extent…”
— Iowa Code § 22.8(l)(a) — 1 case
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). “” Iowa Code § 22.8 (l)(a)-(6). The party opposing disclosure carries the burden of establishing both elements by clear and convincing evidence.”
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