Elizabeth Bright v. State of Iowa

• Court: Supreme Court of Iowa
• Decided: March 14, 2025
• Docket: 24-1019
• Status: Published

Opinion

In the Iowa Supreme Court

No. 24–1019

Submitted February 11, 2025—Filed March 14, 2025

Elizabeth Bright,

Appellant,

vs.

State of Iowa,

Appellee.

Appeal from the Iowa District Court for Johnson County, Kevin McKeever,

judge.

Plaintiff appeals the dismissal of her action under the Fraud in Assisted

Reproduction Act. Affirmed.

Per curiam.

James P. Hayes, Karen A. Lorenzen, and Michael H. Biderman of Hayes

Lorenzen Biderman Lawyers PLC, Iowa City, for appellant.

Brenna Bird, Attorney General; Eric H. Wessan, Solicitor General;

William C. Admussen, Assistant Solicitor General; Christopher J. Deist,

Assistant Attorney General; and Pope S. Yamada and Carolyn Russell Wallace of

Phelan Tucker Law L.L.P., Iowa City, for appellee. 2

This case raises the same issue decided in Miller v. State, ___ N.W.3d ___

(Iowa 2025): Whether Iowa Code chapter 714I, the Fraud in Assisted

Reproduction Act (FARA), enacted in 2022, applies retrospectively. We held that

it does not. Id. at ___. Our decision in Miller controls the outcome of this case.

In the 1950s, Barbara Steinkraus and her husband, Warren Steinkraus,

were struggling to conceive a child. The couple sought assistance from the

Department of Obstetrics and Gynecology at the University of Iowa Hospitals and

Clinics in Iowa City. They were seen by Dr. John H. Randall, a state employee

and head of that department from 1952 to 1959, who suggested that the couple

undergo fertility treatment. The treatment was successful, and Barbara gave

birth to a daughter named Elizabeth on July 13, 1958, in Mount Pleasant.

Barbara and Warren Steinkraus as well as Dr. Randall have all passed away.

Elizabeth married and took the last name of Bright.

Bright had always believed that her biological father was Warren

Steinkraus. However, she discovered through DNA testing via Ancestory.com

that Dr. John Randall is her actual biological father. Believing Dr. Randall had

deceived her parents about the identity of the sperm used in their fertility

treatment, Bright asserted a claim against the State in 2023 under the newly

enacted FARA. The State Appeal Board denied her claim, and she filed this civil

action against the State under FARA. The State moved to dismiss Bright’s

petition, arguing that FARA lacks language allowing it to apply to fertility fraud

occurring before its enactment. Bright argued that the legislature intended FARA

to apply retrospectively to the actions taken by healthcare professionals prior to

the statute’s enactment. The district court agreed with the State and dismissed

the case. Bright appealed, and we retained the case. 3

Iowa Code section 4.5 (2024) provides that “[a] statute is presumed to be

prospective in its operation unless expressly made retrospective.” There is no

express language in FARA that allows it to apply retrospectively. In Miller, we

held that FARA does not apply retroactively to fraud that occurred before its

enactment. ___ N.W.3d at ___.

Because Dr. Randall’s actions occurred before FARA’s enactment, FARA is

inapplicable. Applying Miller, we affirm the district court’s judgment dismissing

the case with prejudice.

Affirmed.

This opinion shall not be published.