The Iowa Public Information Board
COMES NOW, Charlotte Miller, Executive Director for the Iowa Public Information Board (“IPIB”), and enters this Investigative Report:
On November 20, 2025, Jonathan Uhl (Complainant) filed formal complaint 25FC:0191, alleging City of Davenport (Respondent) violated Iowa Code Iowa Code Chapter 22.
The IPIB accepted this Complaint on December 18, 2025
Facts
On September 24, 2025, Complaint submitted a public records request, PRR-414-2025, to Respondent pursuant to Iowa Code Chapter 22. The request sought all public records, correspondence, communications, and documentation involving or referencing the complainant, another individual, and any aliases, alternative spellings, pseudonyms, or other identifiers used by either individual or Respondent in connection with public records matters from January 1, 2017 to the present. The request specifically included all public records requests submitted by or on behalf of either individual, associated request numbers and tracking identifiers, any portal login credentials associated with those requests, all communications between Respondent and these individuals, and any internal communications among the respondent officials or departments referencing or discussing requests submitted by either individual. Complainant noted in the request that it was a repeat or substantially similar request to a prior submission and asked that it be fulfilled with minimal effort by relying on previously collected or reviewed records.
Respondent provided Complainant notice of receipt on September 26, 2025.
On November 18, 2025, Complainant followed up with Respondent requesting the status of his complaint, stating that he had repeatedly asked for updates regarding the status of the request but had been met with silence.
On November 20, 2025, Complainant submitted formal complaint 25FC:0191 to the Iowa Public Information Board, alleging that Respondent had failed to respond professionally and was in violation of Iowa law. Complainant also referenced separate litigation then pending against the City for failure to comply with Chapter 22 and asserted that the matter reflected a broader pattern of noncompliance by Respondent.
On December 9, 2025, the IPIB received the formal complaint, 25FC:0191. On December 11, 2025, the IPIB accepted the complaint for further investigation, notifying both parties and directing the City to respond within two weeks. The accepted allegation was failure to produce requested public records.
On February 11, 2026, IPIB staff sent a follow-up inquiry to both parties noting that they had not received a response from either side and asking specifically whether Complainant had received the records responsive to PRR-414-2025.
On February 13, 2026, Respondent submitted its response. Respondent represented that the information requested in PRR-414-2025 had been produced to Complainant as part of numerous other requests. The City noted in particular that a prior request, PRR-300-2025, had resulted in the production of over 6,000 records, most of which required staff to manually open each request individually and download the contained information, all provided at no charge to Complainant. Respondent further stated that within one hour of that production, Complainant had sent an email characterizing the response as incomplete. Respondent also argued, citing IPIB Advisory Opinion 24AO:0003, that the purpose of Chapter 22 is to provide scrutiny of a government body's decision-making activities, and that PRR-414-2025 did not bear on governmental decision-making in that sense. Respondent additionally characterized the request as a repeat or substantially similar request, consistent with language Complainant himself had used in the original submission.
Applicable Law
“Every person shall have the right to examine and copy a public record and to publish or otherwise disseminate a public record or the information contained in a public record. Unless otherwise provided for by law, the right to examine a public record shall include the right to examine a public record without charge while the public record is in the physical possession of the custodian of the public record. The right to copy a public record shall include the right to make photographs or photographic copies while the public record is in the possession of the custodian of the public record. All rights under this section are in addition to the right to obtain a certified copy of a public record under section 622.46.” Iowa Code § 22.2(1).
Analysis
Complainant submitted multiple records requests to Respondent for records. The question is whether the Respondent has violated Chapter 22 by failing to produce the records at issue.
Chapter 22 does not require a government body to produce the same records multiple times. If responsive records have already been provided to a requester in response to a prior request, the government body's obligation under Chapter 22 is satisfied with respect to those records regardless of whether a subsequent request seeks them again. The statute requires that public records be made available upon request; it does not require that a government body conduct duplicative searches and productions of materials already in the requester's possession.
Respondent provides that the records sought in PRR-414-2025 were previously produced to Complainant as part of other requests, and specifically identified prior production PRR-300-2025 as having included the responsive records. Notably, Complainant himself characterized PRR-414-2025 in the request itself as a repeat or substantially similar request to a prior submission, and asked that it be fulfilled by relying on previously collected or reviewed records. It appears that Respondent indicating which previous production contained the responsive records satisfies Complainant’s request.
IPIB Action
The Board may take the following actions upon receipt of a probable cause report:
a. Redirect the matter for further investigation;
b. Dismiss the matter for lack of probable cause to believe a violation has occurred;
c. Make a determination that probable cause exists to believe a violation has occurred, but, as an exercise of administrative discretion, dismiss the matter; or
d. Make a determination that probable cause exists to believe a violation has occurred, designate a prosecutor and direct the issuance of a statement of charges to initiate a contested case proceeding.
Iowa Admin. Code r. 497-2.2(4).
Recommendation
Because Respondent can demonstrate they acted in good faith and compliance with Chapter 22 in searching and identifying responsive records, there is insufficient evidence to find probable cause that a violation of Chapter 22 occurred. Therefore, it is recommended the Board dismiss for a lack of probable cause to believe a violation has occurred.
By the IPIB Executive Director:
_________________________
Charlotte J.M. Miller, J.D.
CERTIFICATE OF MAILING
This document was sent on June 12, 2026, to:
Jonathon Uhl, Complainant
City of Davenport, Respondent
The Iowa Public Information Board
Under Iowa Admin. Code r. 497-2.2(4) the Board takes the following action:
☐a. Redirect the matter for further investigation;
☒b. Dismiss the matter for lack of probable cause to believe a violation has occurred;
☐c. Make a determination that probable cause exists to believe a violation has occurred, but, as an exercise of administrative discretion, dismiss the matter; or
☐d. Make a determination that probable cause exists to believe a violation has occurred, designate a prosecutor and direct the issuance of a statement of charges to initiate a contested case proceeding.
By the Board Chair
___________________________________
Catherine Lucas
CERTIFICATE OF MAILING
This document was sent on June 18, 2026, to:
Jonathon Uhl, Complainant
City of Davenport, Respondent
Areas Served
- Dallas
- Polk