Lonnie Kay Milbrath v. Iowa District Court for Boone County

── Lonnie Kay Milbrath v. Iowa District Court for Boone County ── Court: Court of Appeals of Iowa Date: April 15, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 25-0651 Filed April 15, 2026 _______________ Lonnie Kay Milbrath, Plaintiff, v. Iowa District Court for Boone County, Defendant. _______________ Certiorari from the Iowa District Court for Boone County, The Honorable Ashley Beisch, Judge. _______________ WRIT ANNULLED _______________ Erin Carr of Carr Law Firm, P.L.C., Des Moines, attorney for plaintiff. Brenna Bird, Attorney General, and Benjamin Parrott, Assistant Attorney General, attorneys for defendant. _______________ Considered without oral argument by Greer, P.J., and Schumacher and Chicchelly, JJ. Opinion by Chicchelly, J. 1 CHICCHELLY, Judge. Lonnie Kay Milbrath seeks certiorari relief from her contempt finding for violating a no-contact order (NCO). She argues there was insufficient evidence that she contacted the victim. Upon our review, we annul the writ of certiorari. BACKGROUND FACTS AND PROCEEDINGS In February 2020, Milbrath pleaded guilty to first-degree harassment for sending her daughter threatening text messages. Milbrath was granted a deferred judgment and the district court entered a NCO prohibiting Milbrath from contacting her ex-husband and their daughter. The NCO remained in effect until February 6, 2025. In January 2025, Milbrath sent her ex-husband a Facebook message. Her ex-husband reported the message to the police. Investigating officers determined the Facebook page contained the name, personal information, and photographs of Milbrath. Law enforcement also determined the account was updated in December 2024. Based on this, investigators filed a criminal complaint alleging Milbrath had violated the NCO. The district court set a contempt hearing. At the contempt hearing, Milbrath testified in her own defense. She claimed her phone was stolen and testified she could not remember the login information for the Facebook account. She admitted she knew there was a NCO in effect in January 2025. And she acknowledged the Facebook account was hers but argued she did not send the message. The district court rejected this argument and found Milbrath guilty of violating of a NCO under Iowa Code section 664A.7(1) (2025). And the district court imposed a seven-day jail sentence for the violation. Milbrath 2 petitioned for a writ of certiorari. The supreme court granted the writ and transferred the case to us. DISCUSSION Milbrath argues the evidence is insufficient to support the contempt finding. We generally review certiorari actions for correction of errors at law. Spitz v. Iowa Dist. Ct., 881 N.W.2d 456, 464 (Iowa 2016). On review of a contempt ruling, this court must determine whether substantial evidence exists that would “convince a rational trier of fact that the alleged contemner is guilty of contempt beyond a reasonable doubt.” Christensen v. Iowa Dist. Ct., 578 N.W.2d 675, 678 (Iowa 1998) (citation omitted). In reviewing a contempt finding, we examine the evidence “to ensure that proper proof— substantial evidence—supports the judgment of contempt.” Ervin v. Iowa Dist. Ct., 495 N.W.2d 742, 744 (Iowa 1993). Substantial evidence is evidence that could convince a rational trier of fact that the defendant is guilty of contempt beyond a reasonable doubt. Id. at 744–45. A violation of a NCO is subject to contempt proceedings. Iowa Code § 664A.7. The party alleging contempt has the burden to prove beyond a reas