Lewis v. Jaeger
Annotate this CaseTenant brought claims against her landlord, the City of Dubuque, and a City official (Defendants), asserting that they unlawfully caused her eviction from her apartment. Tenant alleged, among other things, that the conduct of Defendants violated a number of her statutory rights under the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). To the extent the Dubuque ordinance authorized the action of Defendants, Tenant argued the ordinance was preempted by the IURLTA. The district court concluded that Tenant was entitled to the return of her security deposit but denied all other relief. The Supreme Court affirmed in part and reversed in part, holding (1) the ordinance was not preempted by the IURLTA and there was no violation of federal law in this case; (2) the ordinance was not unconstitutionally vague and any procedural due process claim was moot; (3) the landlord violated the IURLTA when he removed the belongings of Tenant from the apartment, and landlord's withholding of Tenant's security deposit was a bad faith violation of IURLTA. Remanded.
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