Relating to interpretation of law in administrative and judicial proceedings under the Iowa administrative procedure Act

This bill concerns the interpretation of law in administrative and judicial proceedings under Code chapter 17A, the Iowa administrative procedure Act. Under current law, a court must reverse, modify, or grant other appropriate relief from agency action in specified circumstances if it determines that substantial rights of the person seeking relief have been prejudiced. Such circumstances include agency action based upon an irrational, illogical, or wholly unjustifiable interpretation of a provision of law whose interpretation has clearly been vested by a provision of law in the discretion of the agency. If interpretation of the provision of law has not been clearly vested in the discretion of the agency, the standard of review is instead whether the agency’s interpretation is erroneous. Current law also provides guidance to a court regarding the determination of the degree of deference to be given to the view of an agency, based on whether a provision of law has vested the agency with discretion over the matter in question. The bill strikes these provisions and instead provides that a court must reverse, modify, or grant other appropriate relief from agency action based upon an erroneous interpretation of a provision of law. The bill additionally prohibits a court, or a presiding officer in a contested case or other administrative action subject to Code chapter 17A, when interpreting a state statute or a rule or other agency document subject to Code chapter 17A, from deferring to an agency’s interpretation of the statute, rule, or document, and instead requires the court or officer to interpret its meaning and effect de novo. The bill requires the court or officer, in an action brought by or against an agency, after applying all customary tools of interpretation, to exercise any remaining doubt in favor of a reasonable interpretation that limits agency authority.