South Construction and Insulation, LLC v. Iowa Workforce Development

CourtCourt of Appeals of Iowa
DecidedMay 22, 2024
Docket23-0494
StatusPublished

This text of South Construction and Insulation, LLC v. Iowa Workforce Development (South Construction and Insulation, LLC v. Iowa Workforce Development) 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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South Construction and Insulation, LLC v. Iowa Workforce Development, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0494 Filed May 22, 2024

SOUTH CONSTRUCTION AND INSULATION, LLC, Plaintiff-Appellant,

vs.

IOWA WORKFORCE DEVELOPMENT, Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Bremer County, Rustin Davenport,

Judge.

A limited liability company challenges the dismissal of its petition for judicial

review. AFFIRMED.

Luke C. Jenson of Jenson Law Firm, PLC, Waterloo, for appellant.

Brenna Bird, Attorney General, and John R. Lundquist, Assistant Attorney

General, for appellee.

Heard by Tabor, P.J., and Greer and Schumacher, JJ. 2

GREER, Judge.

With little direction from our caselaw, when the only two members of a

limited liability company (LLC) have equal shares of membership units but receive

unequal shares of remuneration, is Iowa Workforce Development (IWD) able to

consider the extra amount received by the one member wages? And is the amount

of those wages equal to the excess that one member received above and beyond

the remuneration of the other? Because we find that the answer to both of these

questions is yes, we affirm.

I. Background Facts and Prior Proceedings.

Justin and Randa South are married and the only two members of South

Construction and Insulation, LLC (South Construction), which performs

construction, insulation, and weatherization services. Justin and Randa each own

fifty percent of South Construction’s membership units. In 2016 through 2020,

Justin and Randa each received the following remuneration from the LLC:

Year Justin Randa 2016 $30,700.00 $0.00 2017 $38,550.00 $7,647.00 2018 $50,000.00 $17,500.00 2019 $51,195.65 $18,200.00 2020 $103,195.65 $38,850.00

Phrased differently, Justin received between 5.04 times (in 2017) and 2.66 times

as much remuneration (in 2020) as Randa, despite their equal division of

membership units.

In January 2022, IWD completed an unemployment insurance tax audit of

South Construction focused on the status of three persons working for the

company. Along with questions involving whether some persons working for the 3

company were employees or independent contractors, IWD requested information

about remuneration payments made to the members of South Construction and

the ownership interests of those members. South Construction reported “draws”

made to Justin and Randa but did not report any wages paid. Based on the

information provided by South Construction, IWD calculated what it considered

reportable out-of-proportion remuneration for a period of the previous five years.1

Year Justin Randa Reportable Out-of-Proportion Remuneration 2016 $30,700.00 $0.00 $30,700.00 2017 $38,550.00 $7,647.00 $30,903.00 2018 $50,000.00 $17,500.00 $32,500.00 2019 $51,195.65 $18,200.00 $32,995.65 2020 $103,195.65 $38,850.00 $64,345.65

To arrive at the remuneration it then characterized as wages, IWD subtracted

Randa’s remuneration from Justin’s; determining the difference was not in

proportion to his interest, thus making it reportable out-of-proportion remuneration

or wages under the statute. Specifically, IWD found South Construction liable for

unemployment insurance contributions beginning January 1, 2016, because it

“paid sufficient wages in employment to qualify as a construction employer under

Iowa law.” It calculated the total amount of back unemployment taxes South

Construction owed to be approximately $27,146.96 without consideration of

interest and penalties because “LLC member wages were not reported to [IWD].”

South Construction challenged this characterization and the calculation. A

contested case hearing was held before an administrative law judge (ALJ) in

1 The court found that “[b]oth parties agree on the amounts of remuneration the

Souths received,” but we note in one place the record shows different numbers for Randa in the years 2016 and 2017. As the amounts are not contested on appeal, we ignore the differences. 4

June 2022. At the hearing, Justin agreed that IWD’s numbers for his and Randa’s

remuneration each year were accurate and that he and Randa held equal

membership interests in South Construction. However, he insisted that he was not

an employee of the company,2 but that he was paid because he was “seeking

compensation from the earnings of [his] business.” Noting he took “enough to live

on to pay bills,” he determined the amount of remuneration paid each year based

on “the work, myself, day-to-day operations.” He added that there was a

“difference in what each of us [he and Randa] do, and they’ll be a different draw

for each of us then.” At the same time, he explained that there was no agreement

between him and Randa regarding the amount of remuneration. Randa stated that

the remuneration paid was intended to be a “draw” and agreed that she and Justin

do not have any agreement as to how much they each receive as remuneration.

The ALJ affirmed the IWD audit finding that the payments to Justin in excess of

those to Randa were wages, writing, “every year, Justin South has income in

excess of the remuneration Randa South receives. That means South

Construction remunerated Justin South in excess of that which would have been

paid to him based solely on his membership interest.” The ALJ then concluded

that “[t]hat excess remuneration was for services performed by a member of an

LLC. . . . [I]t must be treated as wages.”

South Construction petitioned for judicial review in July. The district court

dismissed the petition in February 2023, writing first that “[a] person can receive

money from an LLC as a member, which is not compensation for services, and

2 In Justin’s testimony, he referred to the company as a partnership, but we do not

carry forward his improper reference to the company’s legal organizational status. 5

also receive money from an LLC as an employee, which is compensation for

services.” Then, the court found that “because [Justin] was always paid more than

[Randa], the largest amount of remuneration to [Justin] that can be considered

draws in any given year is 100% of the remuneration [Randa] received.” In

addition, it noted that the burden to prove that the money paid was for membership

interest was placed on South Construction and South Construction did not meet

that burden. Thus, it affirmed IWD’s determination that the out-of-proportion

remuneration was wages. Lastly, it accepted IWD’s calculation of wages, rejecting

South Construction’s proposed alternative calculation as “divorced from the

meaning of remuneration and . . . unworkable.” South Construction appeals,

alerting us there are no published appellate opinions to answer its questions.

II. Standard of Review.

Judicial review of an agency decision is governed by Iowa Code

section 17A.19 (2022). See Hagen v. Serta/Nat’l Bedding Co., LLC, 1 N.W.3d 1,

5 (Iowa 2024). We apply the standards in section 17A.19 and determine whether

our application of them produces the same result as that reached by the district

court. Chavez v. MS Tech. LLC, 972 N.W.2d 662, 666 (Iowa 2022). If we reach

the same result, we affirm the judgment of the district court. Mike Brooks, Inc. v.

House, 843 N.W.2d 885, 889 (Iowa 2014).

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