Bomgaars v. State of Iowa (Iowa 2021)

Bomgaars v. State of Iowa, No. 20-0375 (Ia. 2021)

Nature of Case: Inmates appeal the dismissal of their consolidated applications for postconviction relief, arguing that delays in the provision of sex offender treatment prevent meaningful access to parole violating their constitutional right to due process. The district court denied relief, finding that the Department of Corrections was using a logical and rational method for allocating sex offender treatment program placements as they became available.

Holding: The Supreme Court of Iowa affirmed the decision of the district court.  Although the opinion concluded that inmates have a liberty interest in parole, the Court declined to decide whether the Due Process Clause affords an Iowa inmate any substantive right to receive sex offender treatment at a particular time.  Instead, the Court concluded that the Department of Corrections’ current schedule for delivering treatment is reasonable under the circumstances and meets federal and state due process requirements.