Supreme Court of Iowa

Antoine Smith v. City of Cedar Rapids

March 14, 2025

Summary

The court held that an officer has no right under Iowa Code section 80F.1(9) to witness statements or the complete investigative report until the agency decides to impose discipline. It also held that the investigation results required under section 80F.1(3) include the agency's disciplinary determination, so written notice is not required before that decision. The court therefore affirmed summary judgment for the City.