Gary Pettit v. Iowa Department of Corrections

Summary

The Iowa Supreme Court held that a sex offender treatment program classification hearing is part of the inmate disciplinary procedure and is not reviewable under Iowa Code chapter 17A. The court concluded that a postconviction-relief action under Iowa Code section 822.2(f) is the proper method for judicial review, vacated the district court's judgment, and remanded with directions to dismiss the petition.

Holdings

1. A sex offender treatment program classification decision must be reviewed through a post-conviction-relief action under Iowa Code section 822.2(f), not through a chapter 17A petition for judicial review.
2. A sex offender treatment program classification decision is part of the inmate disciplinary procedure because failure to comply can lead to loss of earned-time accrual.
3. The sex offender treatment program classification decision was not other agency action reviewable under chapter 17A.

Questions Presented

1. Whether an Iowa Code chapter 17A petition for judicial review is an available method to challenge an Iowa Department of Corrections sex offender treatment program classification decision.
2. Whether the classification decision is part of the inmate disciplinary procedure excluded from chapter 17A as a contested case.
3. Whether the classification decision constitutes other agency action reviewable under chapter 17A.
4. Whether an Iowa Code chapter 822 post-conviction-relief action is the proper method for judicial review of the classification decision.

Disposition

reversed_and_remanded