Amanda Cooke v. Iowa Department of Health and Human Services

Summary

The court reversed the district court and upheld HHS's founded child abuse assessment against Cooke. It held that HHS lacked delegated authority to interpret the statutory definition of inadequate supervision, so the court independently interpreted the statute and concluded that the reasonable-and-prudent-person inquiry includes objective circumstances associated with the caregiver's role as a trained, registered childcare provider. Applying that interpretation, the court determined that Cooke failed to provide proper supervision by violating safe-sleep requirements and leaving the infant unsupervised in a basement with a blanket in the sleeping area.