Iowa Supreme Court · No. 24-1160-b
City of Davenport v. Office of Auditor of State of Iowa
Decided April 17, 2026 · appeal from Scott County · Government
What the court decided
AI summary The Iowa Auditor of State sought to use a subpoena to access documents that the City of Davenport claims are protected by attorney-client privilege. The court reversed a lower court's decision that would have allowed the auditor to review these private materials. This means the city's argument regarding the protection of these documents was upheld, and the case must be sent back to the lower court.1
Result: District Court Ruling Reversed and Case Remanded
The court’s own summary
In an action filed by the Iowa Auditor of State to enforce a subpoena, the City of Davenport was granted interlocutory review of district court orders which hold that the Auditor may have access to attorney–client privileged materials. The City contends the district court erred in ruling that Iowa Code section 11.41(3) authorizes the Auditor to review information otherwise protected by attorney–client privilege in connection with an audit, and by failing to require a prima facie showing for conducting an in camera review of the information.
Holding: A city seeks interlocutory review of a district court order determining that the auditor of state may have access to attorney–client privileged materials. District Court Ruling Reversed and Case Remanded.
Judges
- Written by Justice Edward M. Mansfield
- Trial judge: Jeffrey D. Bert, Scott County
Iowa Code it cites
Each links to the bills that change that chapter.