A bill for an act relating to interpretation of law in administrative and judicial proceedings under the Iowa administrative procedure Act.

2025-2026 Regular Session Introduced by Bill Gustoff

HF 36/HF 853 requires courts to interpret agency statutes and rules de novo, denying deference and favoring interpretations that limit agency authority.

Withdrawn.

#administrativeprocedure #administrativeprocedureact #judicialadministration

HF 36 (Renumbered HF 853) — Summary

Purpose and scope

The bill rewrites how courts and administrative authorities interpret statutes, rules, and agency documents that fall under Iowa Code Chapter 17A (Administrative Procedure Act and related judicial administration provisions).

Primary aim: reduce or remove court deference to an agency’s interpretation and require de novo interpretation by courts or presiding officers, with a bias toward interpretations that limit agency authority.

Key provisions and changes

Standard of review for agency interpretation:

Current law allows varying levels of deference to an agency’s interpretation of law based on whether discretion is vested in the agency.
HF 36/ HF 853 strikes those provisions and requires that a court reverse, modify, or grant other appropriate relief from agency action if the agency’s interpretation of a provision of law is erroneous.

Deference to agency interpretation:

Prohibits courts and presiding officers in contested cases or other administrative actions under Chapter 17A from deferring to an agency’s interpretation of a statute, rule, or other agency document.
Instead, courts and officers must interpret the statute, rule, or document de novo (from first principles, without deferring to the agency’s view).

After applying interpretive tools:

In actions brought by or against an agency, after using all customary interpretive tools, any remaining doubt should be resolved in favor of a reasonable interpretation that limits agency authority.

Who/what is affected

Affected actors:

State agencies (and their actions or interpretations)
Courts and presiding officers handling contested cases or administrative actions under Chapter 17A
Litigants and parties in disputes involving agency interpretations of statutes or agency documents

Affected materials:

State statutes, agency rules, and other agency documents subject to Chapter 17A

Procedural and timeline context

Introduced: January 14, 2025

Subcommittee: January 16–22, 2025 (Gustoff, Shipley, Wilburn)

Subcommittee recommendation: January 22, 2025

Committee action:

Subcommittee report: January 22, 2025
Committee vote: January 30, 2025 (Yeas 15, Nays 6)
Committee report: January 30, 2025

Status update:

Committee report approving bill; renumbered as HF 853 (March 7, 2025)

Potential impact and considerations

The bill signals a shift toward rigorous judicial scrutiny of agency interpretations, potentially reducing agency policy latitude.

Could lead to increased litigation over statutory interpretation and more de novo review in administrative matters.

Aligns interpretation with a presumption in favor of limiting agency authority, rather than expanding or entrenching agency discretion.