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Iowa Court of Appeals: Reversing an agency’s fact-based ruling is the “Bigfoot of the legal community”
By Ryan Koopmans
When an administrative agency makes a ruling that depends, at least in part, upon factual determinations, it’s difficult to get that ruling overturned on appeal. This morning, in a two-page opinion, Iowa Court of Appeals Judge Christopher McDonald tells us how difficult:
We begin and end our analysis with the following observation: “The administrative process presupposes judgment calls are to be left to the agency. Nearly all disputes are won or lost there.” Sellers v. Emp’t Appeal Bd., 531 N.W.2d 645, 646 (Iowa Ct. App. 1995) (citations omitted). A case reversing final agency action on the ground the agency’s action is unsupported by substantial evidence or is irrational, illogical, or wholly unjustifiable is the Bigfoot of the legal community—an urban legend, rumored to exist but never confirmed. Here, the employer had a full and fair opportunity to present its evidence and argument to the deputy commissioner and the commissioner without success. The employer challenged the agency’s findings, conclusions, and application of the facts to the law in the district court without success. Like the district court, we have carefully examined the grainy eight millimeter film of the administrative record. We can add little to the thorough and well-reasoned ruling of the district court, and we will not reiterate the same analysis here. We conclude the agency’s findings are supported by substantial evidence, and its decision is not irrational, illogical, unreasonable, unjustifiable, arbitrary and capricious, or legally erroneous. The search for Bigfoot continues. The judgment of the district court is affirmed without further opinion.
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