Nathan Freidhoff, Individually, Michelle Freidhoff and Todd Freidhoff, Individually and as Parents and Next Friends of Nathan Freidhoff v. Johnston Community School District, Mitch Eagles and Brett Becker

Summary

The Iowa Court of Appeals dismissed an interlocutory appeal from the denial of qualified immunity to Johnston Community School District and two employees. The court held that Iowa Code section 670.4A does not apply to the plaintiffs’ common-law tort claims under controlling Iowa Supreme Court precedent, including Doe v. Western Dubuque Community School District. Because the statute did not authorize the appeal, the court dismissed it for lack of appellate jurisdiction.

Holdings

1. Under Doe v. Western Dubuque Community School District and its progeny, Iowa Code section 670.4A's qualified-immunity provision and heightened pleading requirement apply to state constitutional and statutory claims, but not claims asserting only state common-law tort theories.
2. Because section 670.4A does not apply to plaintiffs' common-law tort claims, the defendants were not authorized by section 670.4A(4) to appeal the denial of qualified immunity, and the appeal had to be dismissed for lack of appellate jurisdiction.
3. The amended petition satisfied Iowa's notice-pleading standard because it provided fair notice of the incident, the general nature of the claims, and the facts supporting them; it was not required to identify a specific legal theory or plead ultimate facts supporting every element.

Questions Presented

1. Whether Iowa Code section 670.4A's qualified-immunity defense and heightened pleading requirement apply to plaintiffs' common-law tort claims.
2. Whether the defendants could pursue an interlocutory appeal from the denial of qualified immunity under Iowa Code section 670.4A(4).
3. Whether the amended petition satisfied Iowa's notice-pleading standard.

Disposition

dismissed