Iowa Farm Bureau Fed’n v. Envtl. Prot. Comm’nAnnotate this Case
Susan Heathcote and Carrie La Seur served on the Environmental Protection Commission during a period of time when the Commission considered the adoption of rules to prevent the degradation of Iowa’s water resources. In 2009, the Commission voted to approve two antidegradation rules and procedures, which were approved by the EPA. Plaintiffs sought to overturn the rule and regulation, alleging that Heathcote was disqualified to vote because she engaged in activities in her employment in support of the rule and that La Seur was disqualified to serve on the Commission at the time she voted because she had moved to Montana and lost her status as an elector in Iowa. The district court granted summary judgment to the Commission regarding both Heathcote’s and La Seur’s participation. The Supreme Court affirmed, holding (1) the nature of rulemaking does not disqualify a Commission member from voting to adopt rules she personally and professionally supported; and (2) the disqualification of a Commission member did not invalidate the action taken by the Commission when the disqualification did not undermine the integrity of the process and the public interest supported validating the rule despite the disqualification.