Iowa Individual Health Benefit Reinsurance Association v. State University of Iowa, Iowa State University of Science and Technology, and University of Northern Iowa

Summary

The Iowa Supreme Court held that the Iowa Individual Health Benefit Reinsurance Association retained the capacity to sue its members for unpaid assessments under Iowa Code chapter 504, despite a 2001 amendment deleting an express power to sue from chapter 513C. The court also concluded that the Association was not an administrative department, commission, or board of state government subject to mandatory arbitration under Iowa Code section 679A.19. The court vacated the court of appeals decision, reversed the district court’s dismissal, and remanded the case for further proceedings.

Holdings

1. The Association retained the capacity to sue its members to compel reporting and collect assessments owed under chapter 513C because its general nonprofit-corporation power to sue under chapter 504A remained intact and chapter 513C did not expressly restrict that power.
2. The Association was not subject to mandatory arbitration under section 679A.19 because it was not an administrative department, commission, or board of state government.
3. The court declined to reach the constitutional challenge because the issue was not raised in the district court, although the universities could raise it on remand.

Questions Presented

1. Whether the 2001 amendment to Iowa Code chapter 513C eliminated the Association's statutory capacity to sue its members to compel reporting and collect unpaid assessments.
2. Whether the Association's action was subject to mandatory arbitration under Iowa Code section 679A.19 because the Association was an administrative department, commission, or board of state government.
3. Whether the universities' constitutional challenge to the assessments under article VII, section 1 of the Iowa Constitution could be considered for the first time on appeal.

Disposition

reversed_and_remanded