Case Explained: Joshua Lee Close v. City of Bellevue Iowa; Dennis Schroeder; Ryan Kloft; Shelby Mutzl

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-24 The eighth-circuit affirmed the district court’s dismissal of the family’s complaint against the City of Bellevue and its police officers for failing to protect Angela Prichard from her ex-husband, holding that neither federal nor Iowa law provided a basis for liability. Under federal substantive due process principles established in *DeShaney v. Winnebago County*, the court ruled that the Constitution does not impose an affirmative duty on the state to protect individuals from private violence, and the “state-created danger” exception did not apply because the officers’ alleged conduct was a failure to act rather than an affirmative action increasing the danger. Regarding procedural due process, the court applied *Town of Castle Rock v. Gonzales*, determining that the Iowa statute mandating arrest for no-contact order violations did not create a “legitimate claim of entitlement” protected by the Due Process Clause because police officers retained discretion in assessing probable cause and enforcing the law. Furthermore, under Iowa state law, the court found that the no-contact-order statute contained no express or implied private right of action against law enforcement, and the Municipal Tort Claims Act did not create liability for omissions. The court also rejected claims under the Iowa Slayer Statute and for intentional infliction of emotional distress, noting that the officers’ alleged conduct did not meet the high threshold required for these causes of action. Finally, the court affirmed the denial of the family’s Rule 59(e) motion to amend the complaint as untimely and futile, concluding that the proposed amendments would not have rendered the claims plausible under *Twombly*. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.