Citizens' Aide/Ombudsman v. Miller

HARRIS, Justice.

This case presents a classic conflict between two statutory schemes. For reasons it deemed good and sufficient, the legislature created a confidentiality requirement covering certain reports in the files of an administrative agency. In separate legislation the legislature later vested subpoena power in Iowa’s citizens’ aide/ombudsman (hereinafter citizens’ aide). The clash here occurred when citizens’ aide attempted to subpoena some of these confidential records, the question being which of the statutory schemes must yield to the other. We think, based on principles of…