Auto-Owners Insurance Company v. Iowa Insurance Division

Summary

The Iowa Supreme Court considered whether an insurer could seek judicial review under the Iowa Administrative Procedure Act of the insurance commissioner’s refusal to resolve an insured’s complaint. The court dismissed the appeal as moot after the underlying dispute over cancellation of the insurance policy was resolved.

Holdings

1. The appeal was moot because the dispute over cancellation of the insurance policy had effectively been resolved, and the appeal was therefore dismissed.

Questions Presented

1. Whether Auto-Owners' appeal from the Iowa Insurance Division's refusal to consider the insured's complaint remained justiciable after the underlying insurance dispute was effectively resolved.
2. Whether the district court erred in dismissing Auto-Owners' petition for judicial review for lack of standing under Iowa Code section 17A.19(1).

Disposition

dismissed