Court of Appeals Finds District Court Correct in Holding it Did Not Have Jurisdiction to Hear Claimant's Alternate Medical Care Dispute

 Towns v. Silver Oaks Nursing and Rehabilitation Center, No. 25-0310 (Iowa App. Dec. 17, 2025)

In this somewhat complicated jurisdictional dispute, claimant initially filed an application for alternate medical care, which was denied.  A petition for judicial review resulted in the district court remanding the issue to the agency to redetermine the alternate medical care dispute based on more specific evidentiary findings.  The agency, through a deputy, issued a decision again denying alternate medical care.  Rather than filing an application for judicial review, claimant filed a document captioned "presentment of agency response to remand order for additional factual finding and request for order for hearing transcript and scheduling orders" with the district court. At hearing, defendants challenged jurisdiction, as claimant had not filed a petition for judicial review. Claimant argued the court had retained jurisdiction under its earlier remand order. The court agreed with defendants, found jurisdiction did not exist and dismissed the action.

The appellate court notes that a limited remand for the taking of additional evidence is unlike a remand for further proceedings.  The limited remand is meant to expand the record available and permit the agency to modify its decision while a complete remand contemplates review on the merits. Iowa Code 17A.19(7), (10).  In a limited remand, the court retains jurisdiction. Remanding for further proceedings is sound and in "accordance with the underlying reasons for the exhaustion requirement."

Unfortunately for claimant, the Court concludes that the district court's order was not a limited remand.  Neither party made application to the court to present additional evidence. In this case the initial ruling on judicial review was "missing the essential elements of a limited remand." The district did not indicate the remand was limited or that the court was retaining jurisdiction over the action.  Under these facts, a timely petition for judicial review was a jurisdictional prerequisite and the district court was without jurisdiction to consider claimant's allegations.

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