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Iowa Farm Bureau Federation v. Environmental Protection Comm'n

ELR Citation: 44 ELR 20162
Nos. 12-0827, (Iowa, 07/11/2014)

The Supreme Court of Iowa held that an Iowan who works for an environmental nonprofit group may sit on the state's Environmental Protection Commission and may vote to adopt rules which she actively supports both professionally and personally. The case arose after the commission adopted new water antidegredation rules. A farm association alleged that the commission's approval was invalid because one of the members who worked for an environmental nonprofit that actively supported the rules should have been disqualified to vote due to a conflict of interest. But the nature of rulemaking does not disqualify a commission member from voting to adopt rules she personally and professionally supports. The association also argued that the rules were invalid because another member should have been disqualified to serve on the commission at the time she voted on the rules because she did not satisfy the requirement for members to be eligible Iowa electors. But the disqualification of a commission member does not invalidate the action taken by the commission when, as here, the particular disqualification did not undermine the integrity of the process and when the public interest supports validating the rule despite the disqualification.