Bert Miller and Nancy Duffner v. State of Iowa

Summary

The Iowa Supreme Court affirmed the district court’s dismissal, holding that the Fraud in Assisted Reproduction Act does not apply retroactively to conduct that occurred before its 2022 enactment. Applying the three‑pronged Hedlund test, the Court found no express retroactive language and therefore applied the presumption of prospective operation. It also noted that applying the criminal provisions retroactively would violate the ex post facto clause. Justice Waterman, writing for a unanimous court, reached this conclusion.