Jacobs v. Iowa Department of Transportation

Petitioner received a one-year driver’s license revocation and suspension for failure to submit to chemical testing. The Department of Transportation (DOT) affirmed the ALJ’s decision. Petitioner sought judicial review of the DOT’s ruling. On the thirtieth day after the DOT issued its final decision, the law firm representing Petitioner electronically submitted a petition for judicial review that was received by the Iowa Judicial Branch electronic data management system (EDMS). The next morning, the clerk’s office returned the petition because Petitioner’s address was missing from the electronic cover sheet and the filing had not been described as a “civil-administrative appeal” on that same cover sheet. The law firm resubmitted the petition after correcting the errors. Upon the motion of the DOT, however, the district court dismissed the petition as untimely because it was one day late. The Supreme Court reversed, holding that, for purposes of meeting a deadline, a filing may relate back to the original date it was received by the EDMS when the filing party demonstrates certain conditions are met. Remanded. View "Jacobs v. Iowa Department of Transportation" on Justia Law