UPDATES & ANALYSIS

State immunity bars wrongful imprisonment claim for money damages, Iowa Supreme Court holds

by Rox Laird | July 2, 2025

Eugene Sikora sued the State of Iowa and the Iowa Corrections Director seeking money damages claiming he was wrongly imprisoned for about five months longer than the law allowed due to a miscalculation by the Department of Corrections. The Iowa Supreme Court, in a 4-3 decision, held that Sikora’s claim for money damages for his wrongful imprisonment is barred by the State’s sovereign immunity and that in the absence of a statutory waiver of this immunity, the Iowa Constitution does not provide a right of action for money damages for false imprisonment.

The legal doctrine of sovereign immunity is rooted in the English common law theory that the king can do no wrong and in American law that federal and state governments cannot be sued without their consent.

In 1965, the Iowa Legislature generally waived the State’s common law immunity against civil claims with the Iowa Tort Claims Act (Iowa Code Chapter 669), but the Court said the Act contains an exception for claims against state employees that bars claims such as Sikora’s.

The decision for the Court was written by Justice David May joined by Chief Justice Susan Christensen and Justices Edward Mansfield and Thomas Waterman. Justice Mansfield wrote a separate opinion concurring with the majority. Justices Christopher McDonald, Dana Oxley and Matthew McDermott each filed dissenting opinions.

In all, the combined opinions covered 103 pages with justices in both the majority and in dissent debating core legal principles dating to the American Declaration of Independence and the debates at the 1857 convention where the Iowa Constitution was drafted.

The decision of the Court

Sikora, who was sentenced to prison for up to five years, claimed the State miscalculated his release date, which caused him to be imprisoned nearly five months longer than the law allowed. He raised several claims in his suit seeking money damages against the State and the Department of Corrections director, all of which the Court deemed “functional equivalents” of false imprisonment and thus barred by Iowa Code Section 669.14(4), which says the State’s waiver of sovereign immunity does not extend to false imprisonment claims.

Sikora initially argued in the district court that his wrongful imprisonment violated the Iowa Constitution and that he is thus entitled to money damages, citing the Iowa Supreme Court’s 2017 decision in Godfrey v. State, which said money damages against the State are allowed in certain circumstances. The Court subsequently overruled Godfrey while Sikora’s case was being tried, and as a result the district court dismissed his case.

On appeal to the Iowa Supreme Court, Sikora argued that even if the State may claim sovereign immunity, individual state employees such as the Corrections director cannot. But the Court disagreed, saying it has repeatedly said sovereign immunity bars damage claims for civil wrongs against both the State and State employees acting within their scope of employment.

“But this does not mean that our courts are unable to help persons who are wrongfully detained in Iowa prisons,” Justice May wrote. “If Sikora had asked our courts for nonmonetary relief—like an order to release him from prison—sovereign immunity would not have foreclosed his request.”

The Iowa Legislature has authorized proceedings “to secure relief” because a “person’s sentence has expired … or the person is otherwise unlawfully held in custody or other restraint,” Justice May added. Sikora, however, did not file his suit against the State until three years after his release from prison.

Justice McDonald’s dissent

Writing for himself and joined by Justices Oxley and McDermott, Justice McDonald said he would allow Sikora to proceed with his wrongful imprisonment claims in district court against the individual defendants in their individual capacities.

Iowa Code Section 669.23, which extends the State’s immunity to government officials as applied to Sikora’s claims, is illegal and void, he argued, because it violates the text of Iowa Constitution Article I, Section 1, which provides that “[a]ll men and women are, by nature, free and equal, and have certain inalienable rights—among which are those of enjoying and defending life and liberty.”

Justice McDonald wrote that under common law, and as written in the federal and state constitutions, individuals injured by government officials had the right to sue those officials for relief, including for monetary damages. “The State now claims that its officials can violate this fundamental law and imprison people with impunity,” he wrote.

“The real legal issue in this case is whether the state can change the common law constitutional regime of rights and remedies and extend its immunity, as sovereign, to state employees to bar Sikora’s common law claims arising out of the deprivation of his liberty due to an alleged over-detention,” he wrote, adding that in his view it cannot do so.

“Where, as here, a person’s constitutional right to liberty—to be free from unlawful bodily restraint—has allegedly been violated, the extension of the state’s sovereign immunity to the allegedly offending officials (or the creation of officer immunity) to preclude any potential claim for violation of that right is unduly oppressive and constitutionally forbidden,” he added.

“When our forefathers fought and pledged their lives, fortunes, and sacred honor to establish a new nation, they did not intend to create absolutist federal and state governments whose officials had the authority to imprison them and their posterity with impunity. Not even King George III asserted such power for his officials, and our forefathers attempted to make sure none could assert it here. They understood that tyranny authorized by statute is still tyranny.”

Justice Oxley’s dissent

Justice Oxley writing in dissent joined by Justices McDonald and McDermott agreed with their arguments but wrote separately to say the majority wrongly relied on the Court’s 2020 decision in Wagner v. State (952 N.W.2d 843) to extend sovereign immunity to State employees.

In Wagner, Justice Mansfield explained in his concurring opinion, the Court said sovereign immunity in Iowa barred tort claims against the State and State officials for acts taken within the scope of their employment.

“As my dissenting colleagues explain, the doctrine—and whether it extends beyond the state to also immunize its employees—is much more nuanced than the majority recognizes,” Justice Oxley wrote, “a fact that the majority is able to ignore with a drive-by citation to an inaccurate statement in Wagner.”

Justice McDermott’s dissent

Writing in dissent, Justice McDermott joined by Justices Oxley and McDonald said the right to pursue a common law cause of action for false imprisonment has existed since the Iowa Constitution was enacted in 1857; thus, he said the majority’s conclusion that the law provides no remedy when state officials falsely imprison someone “is both frightening and, as a legal matter, wrong.”

Sikora’s false imprisonment claim is barred against the State itself because the State retained its sovereign immunity for false imprisonment claims in the Iowa Tort Claims Act, but Justice McDermott said Sikora named individual defendants with the Iowa Department of Corrections, in their personal and official capacities he alleges were responsible for his false imprisonment.

Although the majority opinion noted a historic lack of claims against State officials compared to local officials throughout in Iowa’s history as evidence that the State’s employees unlike local government  employees are immune to claims such as Sikora’s, Justice McDermott said that can be explained by the fact that State government has grown only relatively recently in comparison to local governments.

“In short, many of our state administrative agencies did not come into being until many decades after Iowa achieved statehood,” he wrote. “Cases involving civil suits against local officials from Iowa’s founding era show that there was no immunity for government officials generally. Any claim that state officials have always possessed sovereign immunity from civil suits collides with robust historical evidence showing that people unquestionably could sue local officials fulfilling identical duties as their state counterparts today.”

Justice McDermott said the ability to sue for false imprisonment is not only in the interest of the plaintiff but for potential victims: “The ability to bring a false imprisonment claim provides both a remedy to victims and promotes deterrence against further abridgements. The majority’s dismissal of Sikora’s claim leaves him without a remedy despite his having allegedly suffered five months of unlawful confinement. And after today, it is hard to see what disincentive any state prison official would have to unlawfully hold an inmate well beyond his release date.”

Justice Mansfield’s concurrence

Justice Mansfield, joined by Chief Justice Christensen and Justice Waterman, wrote separately to concur with the majority and to respond to the dissenters who, based on their arguments, he said would reintroduce the Godfrey decision, which allowed damages claims to be brought directly under the Iowa Constitution without prior legislative authorization.

“The dissents acknowledge that a significant reason why we overruled Godfrey was its unworkability,” he wrote. “Justice McDonald acknowledges that Godfrey was ‘impractical.’ Justice McDermott describes it as ‘elusive in nature and scope.’ But the dissents fail to confront the same practical difficulties that permeate their own proposals.”

Justice Mansfield said the dissenters would bring back Godfrey through the back door.

“We made the correct decision in 2023 to overrule Godfrey and restore the situation as it was before Godfrey became temporarily the law in 2017. My dissenting colleagues would revive Godfrey in substance if not in name. For the reasons stated in the majority opinion, as well as those set forth above, the district court’s order of dismissal should be affirmed.”

Tags: Iowa Supreme Court 2024-25