The Iowa Public Information Board
COMES NOW, Charlotte Miller, Executive Director for the Iowa Public Information Board (IPIB), and enters this Dismissal Order:
On July 28, 2026, Chad Brewbaker filed formal complaint 26FC:0200, alleging the Office of the Auditor of the State of Iowa violated Iowa Code Chapter 22.
Facts
In the original complaint to IPIB, Complainant alleged that Respondent is in violation of Chapter 22 because its website blocks large language models like OpenAI, Anthropic, and Grok from retrieving information and indexing the reports on the website. It further stated “there is no legitimate administrative process behind hiding Iowa’s public audit data from indexing.”
IPIB staff followed up with the Complainant explaining that there was no evidence that a person had requested and been denied a public record, that an unreasonable fee had been assessed or that an unreasonable delay to a public records request had occurred. Staff requested Complainant provide additional information sufficient to state a violation of the requirements of Chapter 22. No response was received.
Applicable Law
“Upon receipt of a written complaint alleging a violation of Iowa Code chapter 21 or 22, the board shall either: (a) Accept the complaint, following a review of the allegations on their face, having determined that the complaint is within the board’s jurisdiction, appears legally sufficient, and could have merit; or (b) Dismiss the complaint, following a review of the allegations on their face, having determined that the complaint is outside the board’s jurisdiction, appears legally insufficient, is frivolous, is without merit, involves harmless error, or relates to a specific incident that has previously been disposed of on its merits by the board or a court.” Iowa Code § 497-2.1(2).
Analysis
Chapter 22 only delegates enforcement power to this Board when a complaint appears legally sufficient on its face. The allegations posed by the Complainant, even if true, do not state a violation of Chapter 22 that occurred within 60 days of filing this complaint. Therefore, the matter should be dismissed by IPIB as legally insufficient.
Conclusion
Iowa Code § 23.8 requires that a complaint be within the IPIB’s jurisdiction, appear legally sufficient, and have merit before the IPIB accepts a complaint. Due to failure to state a violation of Chapter 21 or 22, it is found that this complaint does not meet those requirements.
IT IS SO ORDERED: Formal complaint 26FC:0200 is dismissed as legally insufficient for IPIB to proceed with an investigation pursuant to Iowa Code § 23.8(2) and Iowa Administrative Rule 497-2.1(2)(b).
Pursuant to Iowa Administrative Rule 497-2.1(3), the IPIB may “delegate acceptance or dismissal of a complaint to the executive director, subject to review by the board.” The IPIB will review this Order on February 19, 2026. Pursuant to IPIB rule 497-2.1(4), the parties will be notified in writing of its decision.
By the IPIB Executive Director
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Charlotte J.M. Miller, J.D.
CERTIFICATE OF MAILING
This draft document was sent via email on August 13, 2026, to:
Chad Brewbaker, Complainant