5/21/2020 4:21:43 PM

IN THE SUPREME COURT OF IOWA

No. 19–1402

Filed May 22, 2020

JANE DOE,

Plaintiff,

vs.

STATE OF IOWA,

Defendant.

Certiorari to the Iowa District Court for Polk County, William A. 

Price, District Associate Judge.

The petitioner seeks review of a district court order denying her 

application for expungement of the record of a dismissed criminal case. 

WRIT SUSTAINED AND CASE REMANDED.

Andrew Duffelmeyer (until withdrawal) and Robert J. Poggenklass 

(until withdrawal), and Alexander Vincent Kornya of Iowa Legal Aid, 

Des Moines, for appellant.

Thomas J. Miller, Attorney General, Louis S. Sloven, Assistant 

Attorney General, and John P. Sarcone, County Attorney, for appellee.
2

McDONALD, Justice.

In 2011, Jane Doe was charged with one count of unauthorized use 

of a credit card. The charge was dismissed. In 2019, having satisfied all 

of her financial obligations in the dismissed case, Doe filed an application 

to expunge the criminal record pursuant to Iowa Code section 901C.2 

(2019). The district court denied Doe’s application on the ground Doe had 

had court-ordered financial obligations remaining in other cases and thus 

had not met the requisite condition set forth in section 901C.2(1)(a)(2). 

The question presented in this appeal is whether the district court erred 

in denying Doe’s application for expungement on the ground Doe had 

court-ordered financial obligations in other cases. This is a question of 

statutory interpretation, and our review is for the correction of errors at 

law. See State v. Doe, 903 N.W.2d 347, 350 (Iowa 2017).

Before addressing the merits, we first address a jurisdictional issue. 

The State contends this court lacks jurisdiction over the case because an 

order denying an application for expungement is not appealable as a 

matter of right. See Iowa Code § 814.6(1). Doe responds that the district 

court acted illegally in denying her application and that this court may 

choose to treat her notice of appeal as a petition for writ of certiorari. See

Iowa R. App. P. 6.107(1)(a) (“Any party claiming . . . an associate district 

court judge . . . acted illegally may commence an original certiorari action 

in the supreme court by filing a petition for writ of certiorari as provided 

in these rules.”); State v. Propps, 897 N.W.2d 91, 97 (Iowa 2017) 

(“Additionally, if a case is initiated by a notice of appeal, but another form 

of review is proper, we may choose to proceed as though the proper form 

of review was requested by the defendant rather than dismiss the action.”). 

We agree with Doe’s response, and we choose to treat Doe’s notice of 

appeal as a petition for writ of certiorari.
3

Turning to the merits of the case, in questions of statutory 

interpretation, “[w]e do not inquire what the legislature meant; we ask only 

what the statute means.” Oliver Wendell Holmes, The Theory of Legal 

Interpretation, 12 Harv. L. Rev. 417, 419 (1899). This is necessarily a 

textual inquiry as only the text of a piece of legislation is enacted into law. 

Any interpretive inquiry thus begins with the language of the statute at 

issue. See Doe, 903 N.W.2d at 350. Using traditional interpretive tools, 

we seek to determine the ordinary and fair meaning of the statutory 

language at issue. See State v. Davis, 922 N.W.2d 326, 330 (Iowa 2019) 

(“We give words their ordinary meaning absent legislative definition.”); In 

re Marshall, 805 N.W.2d 145, 158 (Iowa 2011) (“We should give the 

language of the statute its fair meaning, but should not extend its reach 

beyond its express terms.”); Antonin Scalia & Bryan A. Garner, Reading 

Law: The Interpretation of Legal Texts 33 (2012) [hereinafter Scalia & 

Garner, Reading Law] (defining “fair reading method” as “determining the 

application of a governing text to given facts on the basis of how a 

reasonable reader, fully competent in the language, would have 

understood the text at the time it was issued”). In determining the 

ordinary and fair meaning of the statutory language at issue, we take into 

consideration the language’s relationship to other provisions of the same 

statute and other provisions of related statutes. See Iowa Code § 4.1(38) 

(“Words and phrases shall be construed according to the context and the 

approved usage of the language . . . .”); Doe, 903 N.W.2d at 351 (stating 

we consider the “relevant language, read in the context of the entire 

statute”). If the “text of a statute is plain and its meaning clear, we will 

not search for a meaning beyond the express terms of the statute or resort 

to rules of construction.” In re Estate of Voss, 553 N.W.2d 878, 880 (Iowa 

1996); see State v. Richardson, 890 N.W.2d 609, 616 (Iowa 2017) (“If the 
4

language is unambiguous, our inquiry stops there.”). If the language of 

the statute is ambiguous or vague, we “may resort to other tools of 

statutory interpretation.” Doe, 903 N.W.2d at 351. 

We begin our inquiry in this case with the language of the statute as 

a whole. See State v. Pettijohn, 899 N.W.2d 1, 16 (Iowa 2017) (“Interpreting 

a statute requires us to assess it in its entirety to ensure our interpretation 

is harmonious with the statute as a whole rather than assessing isolated 

words or phrases.”); In re Estate of Melby, 841 N.W.2d 867, 879 (Iowa 

2014) (“When construing statutes, we assess not just isolated words and 

phrases, but statutes in their entirety . . . .”); Scalia & Garner, Reading 

Law at 167 (“Perhaps no interpretive fault is more common than the failure 

to follow the whole-text canon, which calls on the judicial interpreter to 

consider the entire text, in view of its structure and of the physical and 

logical relation of its many parts.”). 

The statute requires the district court to expunge the record of a 

criminal case upon the defendant establishing five conditions have been 

satisfied. The statute provides,

1. a. Except as provided in paragraph “b”, upon 

application of a defendant . . . in a criminal case . . . the court 

shall enter an order expunging the record of such criminal 

case if the court finds that the defendant has established that 

all of the following have occurred, as applicable:

(1) The criminal case contains one or more criminal 

charges in which an acquittal was entered for all criminal 

charges, or in which all criminal charges were otherwise 

dismissed.

(2) All court costs, fees, and other financial obligations 

ordered by the court or assessed by the clerk of the district 

court have been paid.

(3) A minimum of one hundred eighty days have passed 

since entry of the judgment of acquittal or of the order 

dismissing the case relating to all criminal charges, unless the 

court finds good cause to waive this requirement for reasons 
5

including but not limited to the fact that the defendant was 

the victim of identity theft or mistaken identity.

(4) The case was not dismissed due to the defendant 

being found not guilty by reason of insanity.

(5) The defendant was not found incompetent to stand 

trial in the case.

b. The court shall not enter an order expunging the 

record of a criminal case under paragraph “a” unless all the 

parties in the case have had time to object on the grounds that 

one or more of the relevant conditions in paragraph “a” have 

not been established.

Iowa Code § 901C.2. 

When the statute is considered as a whole, it is apparent the statute 

is concerned with only the singular case for which expungement is sought. 

The application for expungement must be filed in “a criminal case”—

singular. Id. § 901C.2(1)(a). The conditions prerequisite to expungement 

repeatedly refer to “the criminal case” or “the case.” Id. § 901C.2(1)(a)(1), 

(3), (4), (5), .2(1)(b). The statute’s use of the definite article “the” 

particularizes “the criminal case” and “the case.” See Nielsen v. Preap, 586 

U.S. ___, ___, 139 S. Ct. 954, 965 (2019) (stating “grammar and usage 

establish that ‘the’ is ‘a function word . . . indicat[ing] that a following noun 

or noun equivalent is definite or has been previously specified by context.’ ” 

(alteration in original) (quoting Merriam-Webster’s Collegiate Dictionary 

1294 (11th ed. 2005))); Am. Bus. Ass’n v. Slater, 231 F.3d 1, 4–5 (D.C. Cir. 

2000) (“[I]t is a rule of law well established that the definite article ‘the’ 

particularizes the subject which it precedes. It is a word of limitation as 

opposed to the indefinite or generalizing force of ‘a’ or ‘an.’ ” (quoting 

Brooks v. Zabka, 450 P.2d 653, 655 (Colo. 1969) (en banc))); State v. 

Hohenwald, 815 N.W.2d 823, 830 (Minn. 2012) (“The definite article ‘the’ 

is a word of limitation that indicates a reference to a specific object.”). “The 

criminal case” and “the case” thus must refer to a particular antecedent. 
6

Here, the antecedent is the singular “criminal case” in which the 

application for expungement was filed and for which expungement was 

sought. See Iowa Code § 901C.2(1)(a). 

The text of the subsection at issue also relates only to the record of 

the singular criminal case in which the application for expungement was 

filed and for which expungement was sought. The text provides the 

defendant must establish as a prerequisite to expungement that “[a]ll court 

costs, fees, and other financial obligations ordered by the court or assessed 

by the clerk of the district court have been paid.” Id. § 901C.2(1)(a)(2). 

The State argues this provision is not limited to the singular case sought 

to be expunged because the provision does not specifically reference “the 

case” or the “criminal case.” However, the State ignores other limiting 

language in the provision. Section 901C.2(1)(a)(2) uses the definite article 

“the” in limiting the financial obligations at issue to those “ordered by the 

court or assessed by the clerk of the district court.” Id. Use of the definite 

article “the” means “the court” and “the clerk” have antecedents and must 

refer to a specific court or a specific clerk. See Am. Bus. Ass’n, 231 F.3d 

at 4–5; Hohenwald, 815 N.W.2d at 830. Here, those antecedents are the 

court that ordered the financial obligations or the clerk that assessed the 

obligations at a particular point in time in the past in “such criminal case.” 

Iowa Code § 901C.2(1)(a)(2). “[S]uch criminal case” refers to the singular 

criminal case in which the application for expungement was filed.

An additional textual consideration shows the provision at issue 

refers only to the criminal case in which the application for expungement 

was filed. Iowa Code section 901C.3 provides a mechanism for the 

expungement of misdemeanor convictions. As a prerequisite to the 

expungement of a misdemeanor conviction, the Code provides the 

defendant must prove she “has paid all court costs, fees, fines, restitution, 
7

and any other financial obligations ordered by the court or assessed by the 

clerk of the district court.” Id. § 901C.3(1)(d). The misdemeanor 

expungement provision specifically identifies “fines” and “restitution” as 

amounts that must be satisfied as a prerequisite to the expungement of a 

misdemeanor conviction. Fines and restitution are financial obligations 

incurred only upon conviction. The absence of this language from the 

expungement provision in section 901C.2(1)(a)(2) strongly shows section 

901C.2 addresses only the financial obligations due in the case in which 

the application for expungement was filed.

In addition to these textual considerations, we must also recognize 

the statute has the patina of prior judicial interpretation. In Doe, the 

defendant was charged with several aggravated misdemeanors in one trial 

information and a simple misdemeanor in a separate complaint with all 

charges arising out of the same operative facts. See Doe, 903 N.W.2d at 

349. Pursuant to a plea agreement, the defendant in that case pleaded 

guilty to a lesser included offense of one count in the trial information, and 

the district court dismissed the remainder of the charges, including the 

separate simple misdemeanor. See id. Doe subsequently sought 

expungement of the record of the simple misdemeanor charge. See id. 

“The fighting issue . . . [was] the meaning of ‘case’ as used in Iowa Code 

section 901C.2. Is a case a particular numbered legal proceeding . . . or 

all the charges arising out of a single transaction or set of circumstances 

. . . ?” Id. at 351. We concluded “case,” within the meaning of section 

901C.2, referred to the particular case file with a separate case number 

for which expungement was sought. See id. at 355. Doe’s conclusion that 

“case” referred to a separate criminal file with a separate case number is 

consistent with our textual analysis that section 901C.2(1)(a)(2) refers to 
8

the financial obligations only in the singular case in which the application 

for expungement was filed and for which expungement was sought. 

The State resists the conclusion that section 901C.2(1)(a)(2) requires 

Doe to establish only that she has satisfied the financial obligations arising 

out of the singular case for which expungement was sought. In the State’s 

view, the statute’s use of “the court” and “the clerk” refer to the court or 

the clerk in the particular county in which the case was filed and thus the 

“plain meaning is that financial obligations arising from other cases in the 

same county would bar the expungement of any case files” in the county. 

In the State’s view, this includes financial obligations in both criminal and 

civil cases. In the State’s view, this interpretation advances the legislative 

purpose of incenting defendants to pay court debt owed to the county in 

which expungement was sought.

We find the State’s interpretation of the statute unconvincing. First, 

the State ignores the structure of the statute as whole. “[W]e read statutes 

as a whole rather than looking at words and phrases in isolation.” Iowa 

Ins. Inst. v. Core Grp. of Iowa Ass’n for Justice, 867 N.W.2d 58, 72 (Iowa 

2015). When an entire statute relates only to a single specific subject, it 

seems reasonable to conclude that all provisions in the statute relate to 

the same subject as a matter of structure and purpose. See Den Hartog v. 

City of Waterloo, 847 N.W.2d 459, 462 (Iowa 2014) (“We have often 

explained we construe statutory phrases not by assessing solely words and 

phrases in isolation, but instead by incorporating considerations of the 

structure and purpose of the statute in its entirety.”). For example, in 

Iowa Insurance Institute we concluded a statute that “waive[d] any privilege 

for the release of . . . information” did not constitute a waiver of work 

product. Iowa Ins. Inst., 867 N.W.2d at 75. We concluded, instead, the 

statute related only to a waiver of protection for medical information 
9

because when the statute was considered as a whole “all the other 

subsections relate[d] to health care services.” Id. at 72. Similarly, here, 

the fact that the statute as a whole relates only to the particular case in 

which the application for expungement was filed counsels in favor of 

reading section 901C.2(1)(a)(2) as also being limited to the particular case 

in which the application for expungement was filed.

Second, we disagree with the State’s purposive interpretation of the 

statute. It is certainly true one of the critical aspects of statutory 

interpretation is to determine the purpose of a statute. The purpose of a 

statute, however, is primarily determined from the language of the statute 

itself. See, e.g., Bd. of Governors of Fed. Reserve Sys. v. Dimension Fin.

Corp., 474 U.S. 361, 373, 106 S. Ct. 681, 688 (1986) (“The ‘plain purpose’ 

of legislation, however, is determined in the first instance with reference 

to the plain language of the statute itself.”). Here, the language of the 

statute does not support the conclusion that the purpose of the statute is 

to incent the payment of court-ordered financial obligations to the 

particular county where the application for expungement was filed. 

Nowhere does the statute indicate the relevant consideration for 

expungement is the defendant’s total court-ordered financial obligations 

to the particular county in which the application was filed. The statute 

does not even use the word “county.” 

In our view, the State’s interpretation is actually contrary to the 

purpose of the statute. “[A] driving concern behind chapter 901C was that 

a member of the general public—such as an employer doing an informal 

background check—could access our computerized docket and potentially 

draw inappropriate inferences from the mere presence of a criminal file 

relating to an individual, even though the criminal charges were dismissed 

or the individual was acquitted.” Doe, 903 N.W.2d at 354. To avoid these 
10

inappropriate inferences and other “stigma,” the statute was enacted to 

facilitate the expungement of the record in criminal cases in which the 

defendant was acquitted or the case was dismissed. Id. Requiring a 

defendant to satisfy financial obligations in cases other than the case for 

which expungement was sought frustrates this statutory purpose. This is 

particularly true with respect to the State’s proposed interpretation that 

requires the satisfaction of all financial obligations in civil cases in the 

same county. 

Consider an example. Iowa Code section 901C.2(1)(a)(3) provides a 

defendant may seek expungement of a criminal file on an expedited basis 

where the “the defendant was the victim of identity theft or mistaken 

identity.” The expedited process allows a victim of identity theft or 

mistaken identity to quickly expunge the criminal record to avoid any 

inappropriate inferences drawn from and stigma associated with a 

criminal charge. See Doe, 903 N.W.2d at 354 (discussing purpose of 

statute). Except, under the State’s interpretation, a victim of identity theft 

or mistaken identity would not be able to avail herself of the statute and 

avoid the stigma associated with criminal accusation if she had unpaid 

financial obligations in a dissolution of marriage case, a personal injury 

case, a landlord–tenant case, a small claims case, or any other civil case

in the county. 

We do not see how including civil obligations within the meaning of 

the statute in any way advances or even remotely relates to the expressed 

statutory purpose of allowing a defendant to expunge the record of a 

criminal case in which the defendant was accused but not convicted of a 

crime. We do understand, however, why the statute would require the 

defendant to satisfy the financial obligation in the particular case at 

issue—(1) the legislature wanted to ensure a defendant paid his or her 
11

obligations in the case at issue before being allowed to exercise the right 

of expungement; and (2) after expungement, it would be practically 

impossible to collect the defendant’s court-ordered financial obligations in 

the expunged case. The lack of any nexus between the State’s proposed 

interpretation of the statutory text and the clear purpose of the statute 

militates against the State’s interpretation. 

In sum, section 901C.2 provides the district court “shall enter an 

order expunging the record of such criminal case” if the defendant 

establishes five requisite conditions. Iowa Code § 901C.2(1)(a). Upon the 

defendant establishing each of the requisite conditions, expungement is 

mandatory. See State v. Klawonn, 609 N.W.2d 515, 522 (Iowa 2000) 

(“Additionally, we have interpreted the term ‘shall’ in a statute to create a 

mandatory duty, not discretion.”). Iowa Code section 901C.2(1)(a)(2) 

requires the defendant to establish she satisfied all financial obligations 

“ordered by the court or assessed by the clerk of the district court” in the 

singular criminal case in which the application for expungement was filed 

and for which expungement was sought. This interpretation of the statute 

follows from the ordinary and fair meaning of the text. This interpretation 

is consistent with the statute’s purpose as expressed in the text of the 

statute. This interpretation is consistent with our prior interpretation of 

the statute in Doe. And this interpretation allows the statute to “be applied 

predictably, quickly, and in a ministerial way.” Doe, 903 N.W.2d at 353. 

For these reasons, the district court erred in concluding section 

901C.2(1)(a)(2) required the defendant to establish she satisfied all 

financial obligations in this case as well as any other case and erred in 

denying Doe’s application on that ground.
12

We grant Doe’s petition for writ of certiorari, sustain the writ, and 

vacate the order of the district court. We remand this matter for further 

proceedings not inconsistent with this opinion.

WRIT SUSTAINED AND CASE REMANDED.

All justices concur except Appel, J., who concurs specially and 

McDermott, J., who takes no part.
13

#19–1402, Doe v. State

APPEL, Justice (concurring specially).

I agree with the result in this case. It seems to me the best 

interpretation of the statute is that the payment of restitution in the case 

at hand is all that is required for expungement. I think the State’s 

interpretation of “all” in the statute is not entirely unreasonable and 

therefore gives rise to a degree of ambiguity. But the State’s position is 

unpersuasive. I come to this conclusion in part because of the language 

of the statute, as ably canvassed by the majority, but also in part because 

the clear legislative purpose of this remedial statute would be substantially 

undermined by the State’s interpretation of the statute. Further, there are 

no persuasive countervailing arguments to the majority’s interpretation 

based upon, for example, any germane legislative history or significant 

linguistic departure from a model statute. So, for me, it is a combination

of text, purpose, and absence of meaningful countervailing considerations, 

that drives the result.

In reaching this result, I do not endorse any sweeping 

methodological statements about textualism as the proper approach to 

statutory interpretation. I fully agree that the starting point of analysis of 

any statute is the language. Analysis of the language matters, and here, 

the case against the State’s interpretation is fairly strong.

But textual analysis is often not the be-all and end-all of statutory 

interpretation and is merely the starting point. Commentators have noted 

the difficulty in relying solely on textual analysis, or so called “plain 

meaning.” See, e.g., State ex rel. Helman v. Gallegos, 871 P.2d 1352, 1359 

(N.M. 1994) (urging caution in applying the plain-meaning rule, stating 

that “[i]ts beguiling simplicity may mask a host of reasons why a statute, 

apparently clear and unambiguous on its face, may for one reason or 
14

another give rise to legitimate (i.e., nonfrivolous) differences of opinion 

concerning the statute’s meaning”); 2A Norman Singer & Shambie Singer, 

Sutherland Statutory Construction § 46.1 (7th ed.), Westlaw (database 

updated Oct. 2019) (describing issues inherent in the plain-meaning rule 

in application); see generally Michael R. Merz, The Meaninglessness of the 

Plain Meaning Rule, 4 U. Dayton L. Rev. 31 (1979) (critiquing the plain 

meaning rule and proposing alternative methods of statutory 

interpretation). A quick look at the legal encyclopedia Words and Phrases

reveals that many frequently used verbal expressions are ambiguous and 

have multiple meanings. Ambiguity arises from not only the meaning of 

particular words, but also “from the general scope and meaning of a 

statute when all its provisions are examined.” Holiday Inns Franchising, 

Inc. v. Branstad, 537 N.W.2d 724, 728 (Iowa 1995). Further, statutory 

terms cannot always be taken literally when considered in context. See 

Iowa Ins. Inst. v. Core Grp. of Iowa Ass’n for Justice, 867 N.W.2d 58, 72 

(Iowa 2015) (“[E]ven if the meaning of words might seem clear on their face, 

their context can create ambiguity.”). Sometimes the text pushes us 

toward absurd results that rightly drive the interpretation away from 

textual literalism. Mall Real Estate, L.L.C. v. City of Hamburg, 818 N.W.2d 

190, 199 (Iowa 2012) (stating that, while the canon of construction noscitur 

a sociis would ordinarily apply, “we cannot apply this canon if its 

application thwarts legislative intent or makes the general words 

meaningless”).

Because of the challenges of statutory interpretation, we have a long 

history of looking to legislative history and statutory purposes as so-called 

“extrinsic aids” in determining the proper approach to statutory 

interpretation. See, e.g., Mulhern v. Catholic Health Initiatives, 799 N.W.2d 

104, 113 (Iowa 2011) (“We also consider the legislative history of a statute 
15

when ascertaining legislative intent.”); Sherwin-Williams Co. v. Iowa Dep’t 

of Revenue, 789 N.W.2d 417, 427 (Iowa 2010) (noting that reliance on 

legislative history, purpose, and definitions are considered, even if it “leads 

to a result that seems contrary to the court’s expectations”). We also 

sometimes consider what was not said in statutes, as when an Iowa 

statute departs from a model act from which it was derived. See, e.g., State 

v. Lindell, 828 N.W.2d 1, 7–8 (Iowa 2013). 

Iowa Code section 4.6 (2019) provides that the court may consider 

seven extrinsic sources in the interpretation of statutes.1 The statute may 

raise serious questions of separation of powers, but there is certainly no 

legislative bar, and in fact we have been permitted, if not encouraged, to 

examine extrinsic indications of legislative purpose. Indeed, one study of 

a ten-year timeframe of our court’s legislative interpretation cases found 

that the three members still on the court today utilized legislative history, 

on average, in 51.7% of the legislative interpretation opinions that they 

authored.2 See generally Karen L. Wallace, Does the Past Predict the 

 1Iowa Code section 4.6 provides,

If a statute is ambiguous, the court, in determining the intention 

of the legislature, may consider among other matters:

1. The object sought to be attained.

2. The circumstances under which the statute was enacted.

3. The legislative history.

4. The common law or former statutory provisions, including laws 

upon the same or similar subjects.

5. The consequences of a particular construction.

6. The administrative construction of the statute.

7. The preamble or statement of policy.”

2This law review article categorized the percentage of statutory interpretation 

opinions that each justice authored that cited historical sources. Justice Mansfield cited 

historical sources in 61.1% of his statutory interpretation opinions, as did Justice 

Waterman in 56.5% of his opinions, and Justice Appel in 37.5% of my opinions. Karen 

L. Wallace, Does the Past Predict the Future?: An Empirical Analysis of Recent Iowa 
16

Future?: An Empirical Analysis of Recent Iowa Supreme Court Use of 

Legislative History as a Window into Statutory Construction in Iowa, 63 

Drake L. Rev. 239 (2015). To the extent the majority opinion’s dicta implies 

that extrinsic aids should not be used to divine legislative purpose or are 

disfavored, it is sailing dead against Iowa Code section 4.6 and the 

established recent practice in this court. As a general rule, we have used 

extrinsic evidence to follow Judge Learned Hand’s admonition not to allow 

hypertextualism “to make a fortress out of the dictionary.” Cabell v. 

Markham, 148 F.2d 737, 739 (2d Cir. 1945).

I have no objection to the result reached in this case; but for me it 

is a combination of text, purpose, and absence of countervailing argument 

that reaches that result. I arrive at that decision in its full statutory 

context. If we are to do our jobs, we judges must continue to have the full 

panoply of intrinsic and extrinsic tools available to us when confronted 

with difficult issues of legislative interpretation. Sometimes the text will 

control. In those cases, there will rarely be appeals. If such cases are 

appealed, they are handled crisply. But when difficult questions of 

statutory interpretation arise, we will need a complete toolbox to make the 

best choices through the art of legislative interpretation.

 

Supreme Court Use of Legislative History as a Window into Statutory Construction in Iowa, 

63 Drake L. Rev. 239, 270 (2015).