Jim Nahas v. Polk County, Iowa

Summary

The court held that Iowa's newly enacted municipal qualified-immunity defense could not apply to alleged conduct occurring before the statute's effective date because the legislature did not expressly make it retrospective. The statute's particularity and plausibility pleading requirements applied to Nahas's post-enactment petitions, but its requirement that the law be clearly established at the time of the violation did not. Applying those standards, the court allowed the libel and civil-conspiracy claims to proceed and dismissed the remaining claims. No separate opinions were filed.