Deborah McFadden’s husband Charles died in a motorcycle accident in April of 2012 on Highway 69 in Warren County. Deborah filed a claim with the state appeal board alleging the DOT’s negligent maintenance of the highway caused his death. After six months of getting no answer from the appeal board, she filed suit in district court.
The district court, and Court of Appeals both threw out her case saying she had not exhausted her appeal through the administrative process before going to court. She appealed those rulings. State officials argued McFadden’s claim was not properly submitted to the appeals board because she had not clearly stated she was the administrator of her husband’s estate in the paperwork she submitted.
The Iowa Supreme Court says McFadden’s claim form answered all the questions required and contained all the information the state administrative rule requires. The court ruling says “the appeal board’s rules and claim form did not require McFadden to allege her representative capacity in presenting the tort claim in this case.” It says McFadden had been appointed administrator before presenting claim to the appeal board, and was entitled to present the claim and file suit in her own name as the estate’s legal representative.
The conclusion of the Supreme Court’s ruling quoted wording from a case more than a century ago:
“[R]ights must not be denied by too strict an application of mere legal formality. The sword of Justice is not often made more keen by the whetstone of technicality, and a right secured by too rigid means may harden into a wrong. . . . Not only must justice appear to be done, but it is the function and duty of this court and of all courts to see that it is done. Technicality should not become a Pegasus which, if ridden by an expert legal jockey, may carry us far from the true goal.”
The Supreme Court vacated the Appeals Court ruling and reversed the district court ruling and sent the case back to district court for action.
Here’s the full ruling: McFadden ruling PDF