## Facts

- Edward J. Hollinrake applied to the Iowa Law Enforcement Academy for certification as a peace officer.
- The Academy applied a minimum vision standard in 501 Iowa Administrative Code 2.1(9), requiring uncorrected vision of not less than 20/100 in both eyes, corrected to 20/20.
- Hollinrake had 20/20 corrected binocular vision, but his left eye did not meet the Academy’s per-eye requirement because it could not be corrected to 20/20.
- The Academy interpreted rule 2.1(9) to require that each eye be at least 20/100 uncorrected and correctable to 20/20.
- Based on that interpretation and Hollinrake’s medical information, the Academy denied certification without conducting a contested-case hearing.
- Hollinrake sought judicial review under Iowa Code chapter 17A; the district court dismissed the petition.

## Issues

1. On a motion to dismiss in a chapter 17A judicial-review proceeding, must the court accept as true the petition’s legal conclusions characterizing the agency action as illegal, arbitrary, or discriminatory?
2. Did the Academy erroneously interpret 501 I.A.C. 2.1(9) by requiring each eye to be correctable to 20/20 rather than only 20/20 corrected binocular vision?
3. Was the Academy required to provide a contested-case hearing before denying certification based on failure to meet the vision standard?
4. Was the denial of certification unreasonable, arbitrary, or capricious under Iowa administrative-law standards?
5. Did the eyesight rule, as applied on this record, violate Iowa Code chapter 601A (civil rights)?

## Decision

- The Iowa Supreme Court affirmed dismissal of the petition for judicial review.
- On a motion to dismiss, only well-pleaded facts are treated as admitted; legal conclusions and characterizations are not.
- The Academy’s per-eye interpretation of rule 2.1(9) was reasonable and entitled to deference.
- No contested-case hearing was required before denying certification where no statute or constitutional provision required a hearing and the decision turned on objective criteria.
- The denial was not arbitrary, capricious, or unreasonable because the Academy applied an established rule to the applicant’s undisputed vision measurements.
- The civil-rights challenge failed on the record presented; the vision standard was treated as a neutral fitness requirement related to job safety and performance.

## Legal Principles

- In judicial review, a motion to dismiss admits well-pleaded facts but not legal conclusions alleging illegality, arbitrariness, or statutory violations.
- Courts defer substantially to an agency’s reasonable interpretation of its own administrative rules, particularly in technical or safety-related areas.
- A contested-case hearing is required only when mandated by statute or constitution; an agency may decide eligibility based on objective criteria without a pre-decision hearing.
- Agency action is not arbitrary or capricious when it rests on a formally adopted standard and application of that standard to the relevant facts.
- A facially neutral physical-qualification rule connected to job-related safety and performance will generally withstand a civil-rights challenge absent a supported showing of discriminatory illegality within the judicial-review framework.

## Conclusion

The court upheld the Academy’s denial of peace-officer certification, holding that the agency reasonably construed its vision rule, was not required to provide a contested-case hearing before applying objective medical criteria, and did not act illegally, arbitrarily, or in violation of the civil-rights statute on the record presented.


Hollinrake v. Iowa Law Enf’t Acad., 452 N.W.2d 598 (Iowa 1990)