Full Opinion

IN THE COURT OF APPEALS OF IOWA _______________ No. 24-1358 Filed October 7, 2026 _______________ Jonathan Hart, Petitioner–Appellant, v. Iowa Electrical Examining Board, Respondent–Appellee. _______________ Appeal from the Iowa District Court for Appanoose County, The Honorable Daniel P. Wilson and The Honorable Myron Gookin, Judges. _______________ AFFIRMED _______________ Jason Wallace Miller of Patterson Law Firm, LLP, Des Moines, attorney for appellant. Brenna Bird, Attorney General, and John R. Lundquist, Assistant Attorney General, attorney for appellee. _______________ Considered without oral argument by Greer, P.J., Badding, J., and Doyle, S.J. Opinion by Greer, P.J. 1 GREER, Presiding Judge. After the Iowa Electrical Examining Board (EEB) found probable cause to charge Jonathan Hart with four counts of violations under Iowa Code chapter 103 (2023),1 an administrative law judge revoked his class “A” journeyman license, class “A” master license, and electrical contractor’s license and fined him a $750 civil penalty in June 2023. After consolidating two appeals related to these charges and reviewing two EEB decisions along with two judicial review determinations, we find that Hart’s two arguments that the EEB lacked authority to suspend his licenses for more than two years and that he was unreasonably treated in his efforts to correct a violation required for reinstatement are without merit under the facts as presented.2 We affirm the district court decisions affirming the EEB’s revocation of Hart’s licenses and imposition of the civil penalty. I. Standard of Review. “Appellate review of the contested case proceeding of a licensing board is for correction of errors at law.” Christiansen v. Iowa Bd. of Educ. Exam’rs, 831 N.W.2d 179, 186 (Iowa 2013). “We apply the standards set forth 1 Hart was charged with four counts: (1) “engaging in willful or repeated violations of Iowa Code chapter 103 by representing himself as or otherwise performing the activities of an electrical contractor and/or a master electrician within the state of Iowa without required licenses”; (2) “engaging in a practice that is harmful or detrimental to the public by aiding or abetting an unlicensed person in performing electrical contracting services”; (3) “engaging in a practice that is harmful or detrimental to the public by commencing an electrical installation that was subject to inspection without first applying for a permit or otherwise timely requesting an inspection of that installation”; and (4) “knowingly making misleading, deceptive, untrue, or fraudulent representations or engaging in a practice harmful or detrimental to the public by fraudulently procuring an electrical permit and/or inspection for an electrical installation performed by [Hart].” 2 The EEB asserts Hart’s challenges go directly to a 2017 settlement agreement and consent order. Hart did not appeal or challenge that agreement and order, so Hart has not preserved error on appeal. See Skaufle v. Iowa Bd. of Med. Exam’rs, No. 07-0875, 2008 WL 942290, at *4 (Iowa Ct. App. Apr. 9, 2008). We opt to address Hart’s appeal issues as related to his current revocations. 2 in the Administrative Procedure Act, Iowa Code ch. 17A, to determine whether our conclusions are the same as those of the district court.” Doe v. Iowa Bd. of Med. Exam’rs, 733 N.W.2d 705, 707 (Iowa 2007). “If we reach the same conclusions as the district court, we affirm; if we reach different conclusions, we may reverse.” Democko v. Iowa Dep’t of Nat. Res., 840 N.W.2d 281, 286 (Iowa 2013). “Agency action is considered arbitrary or capricious when the decision was made ʻwithout regard to the law or facts.’” Irland v. Iowa Bd. of Med., 939 N.W.2d 85, 89 (Iowa 2020) (citation omitted). Similarly, a decision is unreasonable when it is “clearly against reason and evidence.” Stephenson v. Furnas Elec. Co., 522 N.W.2d 828, 831 (Iowa 1994). “An abuse of discretion is synonymous with unreasonableness.” Dawson v. Iowa Bd. of Med. Exam’rs, 654 N.W.2d 514, 519 (Iowa 2002) (cleaned up). II. Analysis. Chapter 103 of the Iowa Code sets out duties of the EEB, which include promulgating and adopting rules establishing wiring standards to “protect public safety and health and property.” Iowa Code § 103.6(1)(a). The EEB is also given the power to “[r]evoke, suspend, or refuse to renew licenses granted pursuant to [the] chapter.” Id. at § 103.6(1)(b); see also id. § 272C.3(2) (establishing authority of licensing boards). And if the EEB suspends a license, Iowa Code section 103.35 limits the term of suspension to “not exceed[] two years.” The EEB exercised its role in November 2016 when it issued a statement of charges against Hart. The charges related to projects where Hart allegedly violated permitting and licensing mandates. To resolve the issues over Hart’s violations, in February 2017, the EEB and Hart entered 3 into an informal settlement agreement and consent order. Hart voluntarily agreed to a suspension of his class “A” master electrician and electrical contractor licenses starting on June 1, 2017, until such time as he completed two conditions. In addition to offering a path to resolve his suspension, the parties also agreed to stay any penalty and dismiss a third count of charges alleged. The agreement read, upon completion, Hart’s licenses would be reinstated after two conditions were met: a. Satisfactory closure through a passing final inspection of all open electrical permits purchased by [Hart] as of the date of this Order. The Board’s Executive Secretary shall provide [Hart] a listing of all such open permits within seven (7) days of the Board’s approval of this Order. b. Installation of a compliant equipment grounding conductor at the Wayne Community School’s softball complex in Corydon, Iowa, per the specifications designated by the project’s electrical engineer. A copy of the relevant work drawing specifying the complaint grounding conductor size is attached to this Order as Exhibit 2. Finally, the agreement also provided that Hart “waive[d] his right to a hearing and all attendant rights, including the right to seek judicial review.” The EEB contends that the voluntary settlement agreement and consent order operated to apply an indefinite suspension of Hart’s licenses. Complicating things, Hart never addressed the requirements related to the outstanding open permits in the first condition. As for the second condition, while Hart made attempts to comply, in the end, he failed to complete the project for various reasons and another contractor finalized the work. Fast forward to April 2022, the EEB again brought four new charges against Hart, who only had an active journeyman electrician license at the time. Acting as an unlicensed electrical contractor or master electrician, Hart performed work in 2021 and 2022 for which he was not licensed. Of 4 the four charges brought, the EEB issued a decision that three of the charges were proven. It revoked all three of his licenses and imposed a civil penalty of $750. Hart sought judicial review of the agency ruling in August 2023. Because one of the bases for revoking Hart’s licenses was that he performed work as an electrical contractor or master electrician when in fact he did not have active licenses, he argued that the EEB exceeded its authority when it held him to an indefinite suspension under the terms of the 2017 informal settlement agreement and consent order. He urged that unless suspended means suspended forever, he should not have been sanctioned for work done after 2019, as Iowa Code section 103.35 prohibited any suspension from lasting over two years. The EEB points to the agreement and consent order signed by Hart and to its own rule that states it “may suspend the license for a specific period of time, or indefinitely, may revoke the license, or may reprimand the licensee.” Iowa Admin. Code r. 661-503.2. In its July 2024 order, on judicial review from the agency, the district court considered the issues raised by Hart but determined the EEB did not exceed its authority in suspending Hart’s licenses. As for Hart’s argument about his compliance with the second condition in the settlement agreement, the court found the agency abused its discretion related to the presentation of evidence and remanded the case back to allow Hart the opportunity to present further evidence. In its reasoning about whether the licenses could remain suspended, the district court found because Hart could not challenge the terms in the voluntary settlement agreement and consent order, his licenses were properly suspended, and the board did not exceed its authority because Hart violated the provisions of chapter 103. Hart appealed from the district court ruling that affirmed the EEB’s decision. 5 On the remand to the agency, after presentation of the additional evidence, the administrative law judge still concluded Hart violated the terms of chapter 103 and again revoked the licenses, noting Hart’s threat to public safety, his lack of remorse, the previous disciplinary action, and the settlement agreement and consent order he signed as considerations for the decision. Hart again petitioned for judicial review in November 2024, arguing grounds under Iowa Code section 17A.19(10)(b), (c), (d), (f ), and (h) through (n). After the district court affirmed the agency’s decision, Hart appealed and the case comes to us as a consolidated appeal from both district court rulings after judicial review. We first note that the district court provided an extensive and detailed review of the procedural history, the facts as developed at the agency stage, and the issues remaining for consideration. As the district court correctly stated: The court shall reverse, modify, or grant other appropriate relief from agency action, equitable or legal and including declaratory relief, if it determines that substantial rights of the person seeking judicial relief have been prejudiced because the agency action falls within any of the categories (a) through (n) in section 17A.19(10). Ultimately, the district court upheld the October 2024 agency decision and summarized its findings: that Hart has not shown a basis for the Court to grant relief in this judicial review. The additional evidence shown at the remand hearing only goes to show that Hart knew, at the time he signed the Consent Order, that he was required to install a compliant grounding conductor and two parallel runs [at the softball field]. His installation of a noncompliant grounding conductor then led him to remove the wires. The removed wires were then deemed unusable or damaged. So the requirement of “new wire” was not unreasonable. 6 As for the competitor being allowed to install half the amount of wire, the Court does not know the circumstances of how that agreement was reached and what factors were involved. The Court only knows that Hart agreed to the Consent Order and did not complete the required items. His allegations of “bait and switch” are unfounded; the additional requirement of “new wire” came about because of his own actions. From these findings, the district court concluded that “the Board did not act unreasonably, arbitrarily, capriciously, or otherwise abuse its discretion in finding that Hart’s licenses should be revoked, nor in finding that he had not fulfilled the conditions in the consent order.” It affirmed the EEB’s decision in full. A. Indefinite Suspension Challenge. As the district court found, the EEB did not abuse its discretion or act unreasonably by revoking Hart’s electrical licenses. We see this as not an issue about authority, but a question of what the agreement required. As he agreed, Hart’s licenses were to be suspended until he completed the two conditions. He did not complete either one. Thus, his decision to work as either an electrical contractor or a master electrician, without a proper state license, violated the requirements of chapter 103. Like the situation in Dawson, Hart expressly agreed to the continuing suspension in lieu of facing the charges posed back in 2017. See Dawson, 654 N.W.2d at 519–20 (finding that an agreement with the medical board to subject himself to competency testing was exactly the condition Dawson imposed upon himself and thus, he waived the right to object). Here, there was a benefit to the bargain if Hart met the two conditions required in the settlement agreement and consent order. And as our supreme court has advised, we should not “discourage informal settlements of disciplinary proceedings contrary to legislative intent that such settlements be 7 encouraged.” Id. at 520; see Iowa Code § 17A.10(1) (“Unless precluded by statute, informal settlements of controversies that may culminate in contested case proceedings according to the provisions of this chapter are encouraged.”). Thus, we find Hart’s argument about the EEB’s authority to suspend his licenses past the two-year statutory limit not applicable to the facts of this case given the settlement agreement and consent order terms. B. Unreasonable Treatment by the EEB. Hart argues the EEB acted unreasonably and abused its discretion when it prevented Hart from satisfying the second condition related to the electrical work he started at the Wayne Community School District softball field. Hart argued there were many reasons for his inability to finish the softball field project, but he blames the change in requirements for the project on the EEB because they “mandated” new conductors be installed, instead of reusing the existing conductors. We will defer to a board’s decisions in a “highly technical area if they are within the zone of reasonableness.” Off. of Consumer Advoc. v. Utils. Bd., 452 N.W.2d 588, 592 (Iowa 1990). That is the case here. Likewise, we again turn to the settlement agreement and consent order signed by Hart. Both the agency decisions and the rulings upon judicial review provided extensive detail about how the project under the second condition was handled by Hart and how it was not successfully completed under his direction. The second condition in the settlement agreement required installment of a “compliant equipment grounding conductor.” We do not find any of the reasoning to be arbitrary or unreasonable when the EEB required Hart to install what constituted “compliant” work as recommended by the state electrical inspector, employed by the state fire marshal. See Irland, 939 N.W.2d at 89 (“Agency action is considered arbitrary or capricious when the decision was made ʻwithout regard to the law or facts.’” 8 (citation omitted)). The EEB did not abuse its discretion in following these recommendations. See Banilla Games, Inc. v. Iowa Dep’t of Inspections & Appeals, 919 N.W.2d 6, 19 (Iowa 2018) (“Discretion is abused when it is exercised on grounds clearly untenable or to an extent clearly unreasonable.” (citation omitted)). The fact that later a different electrical contractor found another solution to finish the work is not relevant to what Hart agreed to do under his settlement agreement. “The district court reviews the agency’s decision in an appellate capacity. In turn, we review the district court’s decision to determine whether it correctly applied the law.” Hawkeye Land Co. v. Iowa Utils. Bd., 847 N.W.2d 199, 207 (Iowa 2014) (cleaned up). Thus, in our role, after applying the standards set in Iowa Code 17A.19(10), we cannot find that the agency acted unreasonably, arbitrarily, or abused its discretion. Hart agreed to terms that required him to handle the softball complex work in a certain manner. He did not get that accomplished, and so the settlement agreement and consent order applied to hold the suspension indefinitely and Hart was not prejudiced by the agency action. III. Conclusion. Because we reach the same conclusion as the district court, we affirm its decision. See Democko, 840 N.W.2d at 286. AFFIRMED. 9