Iowa Supreme Court Unanimously Overturns 2017 Godfrey Precedent Establishing Direct Damages Claims Under Iowa Constitution

May 5, 2023

By: Matthew A. McGuire

In an opinion filed May 5, 2023 in Burnett v. Smith and State of Iowa, the Iowa Supreme Court overruled its 2017 opinion in Godfrey v. State, which recognized a private right of action for damages against State officials for violations of the Iowa Constitution.


In this case, the plaintiff, a garbage truck driver, sued an Iowa Department of Transportation (IDOT) officer and the State of Iowa for damages arising out of a traffic-stop-turned-arrest that resulted in the plaintiff’s acquittal. The plaintiff, pleading a damages claim under the Iowa Constitution pursuant to Godfrey, alleged that the officer violated his rights under, among other provisions, article I, section 8 of the Iowa Constitution, which prohibits unreasonable searches and seizures. The district court dismissed the plaintiff’s claim on summary judgment, finding no constitutional violation.


On appeal, the State argued that the district court’s summary judgment analysis was correct. But the State also argued that Godfrey was wrongly decided and should be overruled. Writing for a unanimous Court, Justice Edward Mansfield agreed.


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