Eugene Sikora sued the State of Iowa and the Iowa Corrections Director seeking money damages claiming he was wrongly imprisoned for about five months longer than the law allowed due to a miscalculation by the Department of Corrections. The Iowa Supreme Court, in a 4-3 decision, held that Sikora’s claim for money damages for his wrongful imprisonment is barred by the State’s sovereign immunity and that in the absence of a statutory waiver of this immunity, the Iowa Constitution does not provide a right of action for money damages for false imprisonment.
The legal doctrine of sovereign immunity is rooted in the English common law theory that the king can do no wrong and in American law that federal and state governments cannot be sued without their consent.
In 1965, the Iowa Legislature generally waived the State’s common law immunity against civil claims with the Iowa Tort Claims Act (Iowa Code Chapter 669), but the Court said the Act contains an exception for claims against state employees that bars claims such as Sikora’s.
The decision for the Court was written by Justice David May joined by Chief Justice Susan Christensen and Justices Edward Mansfield and Thomas Waterman. Justice Mansfield wrote a separate opinion concurring with the majority. Justices Christopher McDonald, Dana Oxley and Matthew McDermott each filed dissenting opinions.
In all, the combined opinions covered 103 pages with justices in both the majority and in dissent debating core legal principles dating to the American Declaration of Independence and the debates at the 1857 convention where the Iowa Constitution was drafted.
The decision of the Court
Sikora, who was sentenced to prison for up to five years, claimed the State miscalculated his release date, which caused him to be imprisoned nearly five months longer than the law allowed. He raised several claims in his suit seeking money damages against the State and the Department of Corrections director, all of which the Court deemed “functional equivalents” of false imprisonment and thus barred by Iowa Code Section 669.14(4), which says the State’s waiver of sovereign immunity does not extend to false imprisonment claims.
Sikora initially argued in the district court that his wrongful imprisonment violated the Iowa Constitution and that he is thus entitled to money damages, citing the Iowa Supreme Court’s 2017 decision in Godfrey v. State, which said money damages against the State are allowed in certain circumstances. The Court subsequently overruled Godfrey while Sikora’s case was being tried, and as a result the district court dismissed his case.
On appeal to the Iowa Supreme Court, Sikora argued that even if the State may claim sovereign immunity, individual state employees such as the Corrections director cannot. But the Court disagreed, saying it has repeatedly said sovereign immunity bars damage claims for civil wrongs against both the State and State employees acting within their scope of employment.
“But this does not mean that our courts are unable to help persons who are wrongfully...
