State of Iowa v. Jane Doe

APPEL, Justice (dissenting).

I. Introduction.

In 2009, Jane Doe was indigent. The state charged her with two crimes. The district court appointed counsel because her income was "at or below 125% of guidelines" and she was "unable to pay an attorney." The charges were then dismissed. All that remains of the episode are a record of the dismissed charges, the burden on Doe's life created by that record, and attorney fees she owes to the state.

In the proceedings below, Doe moved to expunge the record of dismissed charges pursuant to Iowa Code section 901C.2 (2017). Recognizing that section…