Dr. Paul R. Gausman v. Sioux City Community School District, Daniel D. Greenwell, Jan George, Taylor Goodvin, and Bob Michaelson

── Dr. Paul R. Gausman v. Sioux City Community School District, Daniel D. Greenwell, Jan George, Taylor Goodvin, and Bob Michaelson ── Court: Supreme Court of Iowa Date: April 17, 2026 Category: General In the Iowa Supreme Court No. 24–1309 Submitted March 24, 2026—Filed April 17, 2026 Paul R. Gausman, Appellee, vs. Sioux City Community School District, Daniel D. Greenwell, Jan George, Taylor Goodvin, and Bob Michaelson, Appellants. Appeal from the Iowa District Court for Woodbury County, Jeffrey A. Neary, judge. A school board appeals and a former superintendent cross appeals from a district court order involving the legality of two school board meetings under the Iowa Open Meetings Act. Appeal Reversed; Cross-Appeal Affirmed. McDonald, J., delivered the opinion of the court, in which all justices joined. Jason M. Craig (argued) and Brett S. Nitzschke of Ahlers & Cooney, P.C., Des Moines, for appellants. Stanley E. Munger (argued) of Munger, Reinschmidt & Denne, LLP, Sioux City, for appellee.  2 McDonald, Justice. Under Iowa’s Open Meetings Act, all “[m]eetings of governmental bodies . . . shall be held in open session unless closed sessions are expressly permitted by law.” Iowa Code § 21.3 (2022). The Act lists twelve exceptions under which a governmental body may hold a closed session. Id. § 21.5(1)(a)–(l). When a governmental body properly invokes an exception, the “governmental body shall not discuss any business during [the] closed session which does not directly relate to the specific reason announced as justification for the closed session.” Id. § 21.5(2). The school board of the Sioux City Community School District held two closed sessions in 2022 that are at issue in this appeal. The justification for the first was to “evaluate the professional competency of an individual whose . . . performance . . . [was] being considered” Id. § 21.5(1)(i). The justification for the second was to “review or discuss records which are required or authorized by state or federal law to be kept confidential.” Id. § 21.5(1)(a). We must decide in this appeal whether the discussion during the first meeting exceeded the scope of the announced justification and whether the records discussed during the second meeting were “confidential.” I. Paul Gausman served as the superintendent of the Sioux City Community School District from July 1, 2008, until June 30, 2022. In November of 2021, Gausman attended a meeting of the Iowa Association of School Boards in Des Moines. Then school board member Perla Alarcon-Flory and incoming board members Jan George and Bob Michaelson also attended the event. Following the formal programming, the four individuals decided to socialize at the hotel bar. As the evening progressed, Gausman urged George to vote Alarcon-Flory for board president. George described it as a “quid pro quo” conversation. Gausman  3 had a similar conversation with Michaelson regarding board leadership. It made Michaelson uncomfortable. George and Michaelson recall Gausman offering his support for the board’s priorities in exchange for their Alarcon-Flory vote, but Gausman testified that he did not offer anything in exchange for votes and simply expressed his opinion regarding who would provide the best board leadership. In the months that followed, George and Michaelson approached board president Daniel Greenwell and asked to discuss the Des Moines conversations as a full board. Greenwell responded that they could discuss those concerns at Gausman’s upcoming regularly scheduled performance evaluation. Gausman’s quarterly performance evaluation was scheduled for January 24, 2022. Gausman requested the evaluation be conducted in closed session, as he had done in the past and as was consistent with