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Case No. 20-0710

Rickie Rilea
v.
State of Iowa, Iowa Department of Transportation, David Lorenzen, in His Official Capacity of Director of the Iowa Department of Transportation Motor Vehicle Enforcement Division, Mark Lowe, in His Official Capacity as the Director of the Iowa Department

In 2016, Rickie Rilea received and paid a traffic citation issued by an Iowa Department of Transportation Motor Vehicle Enforcement Officer. At the time, IDOT officers lacked the legal authority to issue such citations. Rilea brought an unjust enrichment claim against the State of Iowa, the IDOT, and several individual defendants arguing it was unlawful to collect a fine for the improperly issued citation and the defendants were thus unjustly enriched. The district court granted summary judgment to the defendants. The court found the individual defendants and the IDOT were not unjustly enriched. The court also found the claim is an impermissible collateral attack on Rilea’s criminal judgment. Rilea appeals arguing that he is not barred from seeking an unjust enrichment claim under the collateral attack doctrine.

County:
Polk

Appellants

Rickie Rilea

Appellees

State of Iowa, Iowa Department of Transportation, David Lorenzen, in His Official Capacity of Director of the Iowa Department of Transportation Motor Vehicle Enforcement Division, Mark Lowe, in His Official Capacity as the Director of the Iowa Department

Attorneys for Appellants

Brandon Brown
Jessica Donels

Attorneys for Appellees

David S. Gorham
Robin G. Formaker

Supreme Court

Oral Argument Schedule

Non-Oral

Mar 23, 2021 9:00 AM

Briefs

Supreme Court Opinion

Opinion Number:
20-0710
Date Published:
May 14, 2021
Date Amended:
Jul 19, 2021

Other Information

Date Retained:
Dec 01, 2020

View archived opinions from prior to November 2017

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