Discussion. As noted in In re Bishop, 346 N.W.2d 500, 503 (Iowa 1984), chapter 279 of the Iowa Code governs teacher terminations and other matters. If a teacher is dissatisfied with the board's decision, the teacher may appeal to an adjudicator.
Iowa courts interpreting the revised version of Iowa Code Chapter 279 have indicated that the sole remedy for teachers contesting the termination of an employment contract is to pursue the procedures set forth in the relevant statutes. See Walthart v. Bd. of Dir. of Edgewood-Colesburg Cmty. Sch. Dist., 667 N.W.2d 873, 878 (Iowa 2003); Bishop v. E. Allamakee Cmty. Sch. Dist. (In re Bishop), 346 N.W.2d 500, 503-04 (Iowa 1984); Wollenzien v. Bd. of Educ. of the Manson Cnty. Sch. Dist., 297 N.W.2d 215, 217-18 (Iowa 1980). The Iowa Supreme Court addressed this issue in Wollenzien, 297 N.W.2d at 216-18.
Because no suspect class or fundamental right is involved here, we apply the traditional rational basis test. See Bishop v. Eastern Allamakee Community School District, 346 N.W.2d 500, 505 (Iowa 1984); Stracke, 841 N.W.2d at 733. State statutes are clothed with a presumption of constitutionality.
Under the rational basis test, a legislative classification is upheld if any conceivable state of facts reasonably justify it. Bishop v. Eastern Allamakee Community School District, 346 N.W.2d 500, 505 (Iowa 1984) (citation omitted). Kent failed to meet this heavy burden.
The statute of limitation reasonably confines claims to a fixed, but adequate, duration. See Bishop v. Eastern Allamakee Community Sch. Dist., 346 N.W.2d 500, 506-07 (Iowa 1984) (recognizing state's right to enact reasonable procedural requirements for commencement of litigation). No procedural deprivation of constitutional magnitude has been shown.
That leaves only the question whether Burnham substantially complied with the statutory requirement that the sheriff be given notice of the appeal. Substantial compliance exists when the action taken, although not literally satisfying the statutory requirement, nevertheless fulfills the minimal objectives of the statute. Superior/Ideal, Inc. v. Board of Review, 419 N.W.2d 405, 407 (Iowa 1988); In re Bishop, 346 N.W.2d 500, 504 (Iowa 1984). The obvious purpose of giving notice of an appeal is to inform the person entitled to notice that an appeal has been taken.
Allied has failed to show that similarly situated litigants are not being treated equally under Iowa Code section 535.3, and has failed to show that Iowa Code section 535.3 is patently arbitrary and bears no rational relationship to a legitimate governmental interest. See In re Matter of Bishop, 346 N.W.2d 500, 505 (Iowa 1984). Therefore, Allied's equal protection claim must fail.
To prevail on this challenge the Mills would have to prove that no conceivable state of facts could justify the statute. In re Bishop, 346 N.W.2d 500, 505 (Iowa 1984). This they cannot do.
The legislature may classify litigants and adopt certain procedures for one class and different procedures for other classes, so long as the classification is reasonable. All that is required is that similarly situated litigants be treated equally.Bishop v. Eastern Allamakee Community School Dist., 346 N.W.2d 500, 505 (Iowa 1984) (citations omitted). The plaintiffs in this case claim that section 668.11 cannot withstand equal protection scrutiny, even under a rational basis analysis, because it bears no rational relationship to a legitimate state interest.
To overcome the presumption of legislative constitutionality, FLB must prove that no conceivable state of facts could justify the class distinction drawn by the statute. In re Bishop, 346 N.W.2d 500, 505 (Iowa 1984). This deferential scrutiny is particularly appropriate where, as here, the state is exercising its police power in the realm of economic policy and regulation. New Orleans v. Dukes, 472 U.S. at 303, 96 S.Ct. at 2516, 49 L.Ed.2d at 517.