Cities may have dodged a procedural nightmare in Iowa Supreme Court’s ‘Field of Dreams’ ruling

By: Rox Laird on December 13th, 2016

Last week’s Iowa Supreme Court ruling upholding a Dyersville rezoning decision may have gotten the attention of movie fans and baseball nostalgia buffs who remember the 1989 movie “Field of Dreams” filmed on location near the Dubuque County town.

But the decision might also be of interest to elected city officials for what the decision said about municipal rezoning procedures.

The Court ruled unanimously that the Dyersville City Council acted in accord with state law and its own ordinances in rezoning from agriculture to commercial the “Field of Dreams” site for development as a tourist destination with 24 baseball and softball diamonds for regional tournaments. The site had recently been annexed into the city.

About two dozen Dyersville residents and adjacent property owners worried about the impact of traffic and crowds challenged the rezoning on grounds that, among other things, the Dyersville City Council’s action violated state law and the city’s comprehensive plan.

The Supreme Court, in a unanimous decision written by Justice Bruce Zager, rejected each of the petitioners’ claims.

A key issue was the Court’s conclusion that, in rezoning the site, the city council acted in a legislative capacity. Had the Court ruled that the council acted in a judicial capacity – as the objecting neighbors asserted – the case likely would have turned out differently. And all Iowa cities might have been affected in how they handle rezoning requests.

The petitioners argued that if a vote to rezone property is a quasi-judicial action, the council was required to act more like a court than a legislative body. But, rather than conducting impartial proceedings, petitioners said the city council members were biased in favor of the proposed development from the beginning and failed to follow procedural requirements of Iowa law and city ordinances.

The Court disagreed.

“The city council decision to rezone was not undertaken to weigh the legal rights of one party (the All-Star Ballpark Heaven) versus another party (the petitioners),” Zager wrote for the Court. Rather, “the council weighed all of the information, reports, and comments available to it in order to determine whether rezoning was in the best interest of the city as a whole.”

Ultimately it is for the voters to judge the council’s decision, as Justice David Wiggins pointed out in a special concurrence with the decision: “Our decision does not mean that the actions of the city council are not beyond the reach of the persons they were elected to serve. At the next election, the council’s actions are subject to review by the electorate.”

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On Brief is devoted to appellate litigation, with a focus on the Iowa Supreme Court, the Iowa Court of Appeals, and the United States Court of Appeals for the Eighth Circuit.
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