Carlson, et al. v. Justice David Wiggins, et al., No. 11-1374 (8th Cir. 2012)
Annotate this CasePlaintiffs filed a complaint and moved for a temporary restraining order and preliminary injunction, alleging section 16, article V, of the Iowa Constitution, as implemented by Iowa Code sections 46.2, 46.4-46.10, and 46.14, violated their Fourteenth Amendment right to equal protection under the laws. The court concluded that the State Judicial Nominating Commission was a "special limited purpose" entity for its sole function was to select the most qualified candidates for judicial appointments and forward the names of these candidates to the Governor for a final appointment. This narrow function had a disproportionate effect on a definable group of constituents - members of the Iowa Bar - over other voters in the state. Therefore, the election of the attorney members of the Commission was an election of special interest. Applying rational basis review, the court agreed that the district court's Iowa system of election for the Commission's attorney members by and from members of the Iowa Bar was rationally related to Iowa's legitimate interests. Therefore, Iowa's system did not violate plaintiffs' rights under the Equal Protection Clause. Accordingly, the court affirmed the judgment.
Court Description: Civil Case - Constitutional law. Iowa's method of electing attorney members to State Judicial Nominating Commission does not violate the Equal Protection Clause. The Commission does not exercise general governmental powers; it disproportionately affects a definable group of constituents whose interests in a fair and impartial judiciary are different in nature and in scope from the interests of the general public. Thus the Commission is a special limited purpose entity and the system of election for attorneys members need only be rationally related to Iowa's legitimate interests. System bears a rational relationship to legitimate interest in selecting most qualified judges.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.