Marek v. City Development Board of State of Iowa
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In this case arising out of the discontinuance of the City of Mt. Union, the Supreme Court affirmed the decision of the district court dismissing Plaintiffs' claim against the City Development Board, holding that the district court correctly concluded that a petition for judicial review under Iowa Code chapter 17A was Plaintiffs' exclusive remedy against the Board.
Dan and Linda Johnson obtained a default judgment against the City, which had then been discontinued, for defamation, and presented it for payment to the Board, a state agency that supervises the discontinuance of cities. The Board approved the default judgment as a valid administrative claim. Plaintiffs petitioned for judicial review and filed this lawsuit seeking a declaratory judgment. The district court granted summary judgment for Plaintiffs and against the Johnsons in the declaratory judgment action but dismissed Plaintiffs' claim against the Board. The court of appeals reversed the dismissal of the Board. The Supreme Court vacated the court of appeals' decision in part, holding that Iowa Code 368.22 expressly makes chapter 17A "the exclusive means" of judicial review of the Board's actions.
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