The Iowa Department of Corrections (IDOC) allegedly released Eugene Sikora from custody later than it should have after discovering an error in its earned-time calculations. Sikora sued the State of Iowa and directors of the IDOC for money damages. He asserted violations of article 1, sections 1, 8, and 9 of the Iowa Constitution; negligence; negligence per se; false imprisonment; action on the bond; and trespass on the case. Sikora makes two main arguments: (1) the district court improperly dismissed his common law actions, especially for trespass on the case and action on the bond, because they do not “arise out of” false imprisonment under Iowa Code section 669.14(4); and (2) Burnett v. Smith, 990 N.W.2d 289 (Iowa 2023), which overruled Godfrey v. State, 898 N.W.2d 844 (Iowa 2017), and eliminated direct damages actions for constitutional torts, applies only prospectively.

County:

Polk

Trial Court Case No.:

CVCV063762