Latoyia Towns v. Silver Oaks Nursing and Rehabilitation, LLC

CourtCourt of Appeals of Iowa
DecidedDecember 17, 2025
Docket25-0310
StatusPublished

This text of Latoyia Towns v. Silver Oaks Nursing and Rehabilitation, LLC (Latoyia Towns v. Silver Oaks Nursing and Rehabilitation, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Latoyia Towns v. Silver Oaks Nursing and Rehabilitation, LLC, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-0310 Filed December 17, 2025

LATOYIA TOWNS, Petitioner-Appellant,

vs.

SILVER OAKS NURSING AND REHABILITATION CENTER, LLC, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Patrick D. Smith,

Judge.

Latoyia Towns appeals from a district court order that determined the court

lacked jurisdiction to review the Iowa Workers’ Compensation Commissioner’s

decision following remand. AFFIRMED.

Dennis Currell of Currell Law Firm, Cedar Rapids, for appellant.

Tyler C. Block of Kuper Block & Paumer, PC, LLO, Omaha, Nebraska, for

appellee.

Considered without oral argument by Greer, P.J., and Schumacher and

Ahlers, JJ. 2

SCHUMACHER, Judge.

This appeal centers on the jurisdiction of the district court following a

remand after hearing on a petition for judicial review. Latoyia Towns sustained a

work-related injury to her right shoulder during her employment at Silver Oaks

Nursing and Rehabilitation, LLC. Dissatisfied with her employer’s stance on

recommendations from her primary care physician, Towns filed a petition for

alternate medical care. Following the denial of her request for alternate medical

care by the deputy workers’ compensation commissioner, Towns filed a petition

for judicial review in the Polk County District Court challenging the decision. There

is no dispute that Towns’s initial timely petition for judicial review was procedurally

correct.

Following hearing on Towns’s petition for judicial review, the district court

determined that “given the record before the Court, it cannot determine whether

the Commissioner’s decision was irrational, illogical, or wholly unjustifiable.” The

district court remanded the case to the agency for “more specific findings” and

“further analysis” “as to the issues of Towns’[s] notice [of dissatisfaction] to Silver

Oaks, Silver Oaks’[s] notice to Towns, and whether [Towns’s primary care provider

(PCP)] was deemed an authorized provider by Silver Oaks.”

After entry of the order, both parties filed motions pursuant to Iowa Rule of

Civil Procedure 1.904. The court denied Silver Oaks’s motion and denied Towns’s

motion in part and granted such in part, determining: “This Court feels that the

previously entered order implicitly required the agency to undertake the requested

actions, but this ruling will make that request explicit. Additional hearing and

supporting documents are necessary for a decision by the agency.” 3

Following remand and hearing, the deputy entered a decision denying

Towns’s petition for alternate medical care. The deputy’s order further stated it

was “delegat[ed] authority” “to issue final agency decisions on applications for

alternate care”; “[c]onsequently, this decision constitutes final agency action, and

there is no appeal to the commissioner. Judicial review in a district court pursuant

to Iowa Code chapter 17A is the avenue for an appeal.”

It is at this point where the jurisdictional dispute arises. Towns did not file

a petition for judicial review following the commissioner’s decision but instead filed

a document captioned “presentment of agency response to remand order for

additional factual findings and request for order for hearing transcript and

scheduling orders.” Towns challenged the deputy’s decision and requested, in

part, that the district court “direct the agency to enter an award of alternate medical

care entitling Ms. Towns to proceed with the care recommendations from her

PCP.”

The district court scheduled a hearing. At the hearing, Silver Oaks disputed

the court’s jurisdiction. Silver Oaks maintained that Towns was required to file a

petition for judicial review to invoke the court’s jurisdiction to review the remand

decision. But Towns argued the district court retained jurisdiction because it had

ordered remand for the limited purpose of receiving additional factual findings on

the specific issues requested by the court. The district court agreed with Silver

Oaks and ordered: “[T]he court does not have jurisdiction to review the

Commissioner’s Remand Decision. The court takes no further action, and the

Remand Decision stands as the final decision.” 4

Towns appeals, claiming the district court erred in finding it was without

jurisdiction as the court previously ordered a “limited remand,” which did not result

in final agency action reviewable only by a petition for judicial review.1

We begin our analysis with the following. A limited remand contemplated

by the section of the administrative procedure act which allows a court to order the

taking of additional evidence is unlike the remand envisioned in the section

providing for a remand for further proceedings. The limited remand is meant to

expand the record available to the district court for judicial review and to permit the

agency to modify its decision on the basis of additional evidence, while a complete

remand contemplates review on the merits and is appropriate where an erroneous

rule of law is applied by the agency or where the record is inadequate for the court

to determine effectively the merits of appeal. Iowa Code § 17A.19(7), (10) (2023);

Reiter v. Iowa Dep’t of Job Serv., 327 N.W.2d 763, 766–67 (Iowa Ct. App. 1982).

In a limited remand, the reviewing court retains its jurisdiction; while in a

remand for further proceedings, the reviewing court loses jurisdiction. See Reiter,

327 N.W.2d at 766–67 (distinguishing between a limited remand and remand for

further proceedings).

There may be instances where the district court is authorized to make an

interlocutory order remanding the case to the agency for further proceedings. See

Iowa Code § 17A.19(7); see also W. Side Transp., Inc. v. Fishel, No. 02-0092,

2003 WL 21542498, at *3 (Iowa Ct. App. July 10, 2003). If this is done, “it is

1 Towns also maintains the deputy’s “remand decision is null and void” because

the “agency exceeded the limits of the remand order.” But because this issue was not decided by the district court, it is not preserved for review. See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). 5

incumbent upon the court to note that the remand is of a limited nature and that

the court is retaining jurisdiction.” Cont’l Tel. Co. v. Colton, 348 N.W.2d 623, 625

(Iowa 1984). Here, the district court did not indicate the remand was limited, nor

did the court indicate it was retaining jurisdiction.

Towns highlights Iowa Code section 17A.19(7), referenced above, which

provides in part:

Before the date set for hearing a petition for judicial review of agency action in a contested case, application may be made to the court for leave to present evidence in addition to that found in the record of the case.

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Related

Reiter v. Iowa Department of Job Service
327 N.W.2d 763 (Court of Appeals of Iowa, 1982)
Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
Bugely v. State
464 N.W.2d 878 (Supreme Court of Iowa, 1991)
Continental Telephone Co. v. Colton
348 N.W.2d 623 (Supreme Court of Iowa, 1984)
Cooper v. KIRKWOOD COMMUNITY COLLEGE
782 N.W.2d 160 (Court of Appeals of Iowa, 2010)

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