David Michael Adcock v. Iowa District Court for Polk County

── David Michael Adcock v. Iowa District Court for Polk County ── Court: Court of Appeals of Iowa Date: April 15, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 24-1640 Filed April 15, 2026 _______________ David Michael Adcock, Plaintiff, v. Iowa District Court for Polk County, Defendant. _______________ Certiorari from the Iowa District Court for Polk County, The Honorable Tabitha Turner, Judge. _______________ WRIT ANNULLED _______________ Arianna Nalani Eddy of Iowa Legal Aid, Cedar Rapids, attorney for plaintiff. Brenna Bird, Attorney General, David Banta, Assistant Attorney General, attorneys for defendant. _______________ Heard at oral argument by Greer, P.J., and Schumacher and Chicchelly, JJ. Opinion by Greer, P.J. 1 GREER, Presiding Judge. In this certiorari action, David Adcock challenges the district court order refusing to discharge his court debt. According to Adcock, the court required him to pay indigent defense fee reimbursement (IDFR) from a twenty-four-year-old criminal case in which the charges were eventually dismissed, with costs to Adcock, including the IDFR and jail fees. Adcock claims the district court acted illegally by (1) failing to apply the twenty-year statute of limitations for actions on judgments in Iowa Code section 614.1(6) (2024) to the IDFR and (2) applying the sixty-five-year charge-off language in Iowa Code section 602.8107(5) to conclude he was still required to pay the debt. As a third challenge, Adcock argues applying the twenty-year statute of limitations for judgments is necessary to uphold the constitutionality of Iowa’s defense-recoupment statute.1 The State’s appellate position is that no statute of limitations applies to a judgment in favor of the State under the doctrine of nullum tempus occurrit regi, which translates to “no time runs against the King.” See Fennelly v. A-1 Mach. & Tool Co., 728 N.W.2d 163, 168 (Iowa 2006) (citation omitted). It argues that the doctrine applies to all citizens, and so there is no constitutional violation. Accepting the State’s position that a statute of limitations does not apply to the restitution judgment entered in favor of the State, we affirm. With that resolution, we reject Adcock’s constitutional arguments because 1 Adcock also argued that the district court did not have jurisdiction to assess any court debt without a conviction, but he withdrew this argument in supplemental briefing this court requested. 2 judgments in favor of the State are treated similarly for all citizens and, in any event, there is a rational basis for the treatment. I. Background Facts and Proceedings. In March 2001, Adcock was charged with domestic abuse assault, enhanced, in violation of Iowa Code section 708.2A(2)(C) (2001). The same day the charges were filed, a no-contact order (NCO) was put in place between Adcock and the complaining party. Adcock applied for and received court-appointed counsel. In July, the district court held a jury trial, and Adcock was found guilty of domestic abuse assault causing bodily injury in case number AG154948 (first domestic assault). The same month, Adcock was charged with a second domestic abuse assault, case number AG157823. In September, Adcock was sentenced to eighteen months for violating the NCO under case number SM240456. In October, there was a sentencing hearing for the first domestic assault. He was sentenced for domestic assault, which was enhanced because Adcock stipulated to a prior dome