First Iowa State Bank v. Iowa Department of Natural Resources

ANDREASEN, Justice.

The Iowa Department of Natural Resources (DNR) appeals from a district court ruling on judicial review. The court reversed the decision of the environmental protection commission of the DNR that held First Iowa State Bank (bank) was liable under Iowa Code section 455B.307(1) (1987) for cleaning up illegally dumped solid waste. In this appeal we must determine if a property owner, who acquired land from an owner who had allowed open dumping on the land, can be held in violation of Iowa’s statute prohibiting dumping of solid waste. On judicial review of agency action, the…