IN THE INTEREST OF B.L. - No. 21-0300 - Appeal affirmed

Aug 21, 2026

Court of Appeals of Iowa decision in the matter of B.L., a minor child, addressing whether Iowa statutes requiring certain juvenile delinquency records to become public for at least two years are constitutional. The appeal challenges the district court’s refusal to keep B.L.’s records confidential and argues the scheme violates constitutional protections against cruel and unusual punishment. The court reviews the underlying juvenile adjudication, statutory confidentiality and sealing procedures, and the asserted risk of continued online availability, then affirms the district court.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages12

Reading Time30 min

AccessFree to download

Background Facts and Proceedings

Motion to keep records confidential

Statutory framework for confidentiality and sealing

Standard of Review

Analysis

Iowa statutory confidentiality directives

Sealing process and constitutional claims

IN THE COURT OF APPEALS OF IOWA No. 21-0300 Filed December 15, 2021 IN THE INTEREST OF B.L., Minor Child, B.L., Minor Child, Appellant. Appeal from the Iowa District Court for Plymouth County, Daniel P. Vakulskas , District Associate Judge. An adjudicated delinquent appeals from the district court’s finding that statutes mandating his records become public for at least two years are constitutional. AFFIRMED. Meret Thali (until withdrawal) and Joseph W. Kertels of Juvenile Law Center, Sioux City, for appellant. Thomas J. Miller, Attorney General, and Mary A. Triick, Assistant Attorney General, for appellee. Heard by Greer, P.J. , Badding, J. , and Carr, S.J.* *Senior judge assigned by order pursuant to Iowa Code section 602.9206 (2021) . 2 GREER, Presiding Judge. In 2017, B. L. was adjudicated delinquent after committing an act against an individual under the age of twelve that, were [B.L. an](B.L. an) adult, would be considered sexual abuse in the second degree , a forcible felony. See Iowa Code § 702. 11(1)(2017) . In 2020, B. L. moved to have the juvenile court retain jurisdiction of his case past his eighteenth birthday 1 to keep his record confidential until the time it could be sealed. After a 2021 hearing on the motion, although the State did not resist, the court dismissed B. L.’s case and waived the requirement that B. L. register as a sex offender. But the court denied the motion to make B. L.’s records confidential. Arguing this action constituted cruel and unusual punishment, B. L. appeals the ruling on his motion. I. Background Facts and Proceedings. We accept as true that, as a teenager, B. L. performed a sex act on a child under the age of [twelve. Were B.L. an](twelve. Were B.L. an) adult, the act would be sexual abuse in the second degree , which is considered a forcible felony. After the court adjudicated [B.L. to](B.L. to) be a delinquent child, he was placed in a residential treatment facility and the requirement that he register as a sex offender was deferred. B. L. spent nearly four years on probation, eventually moving in with step-family members and then his parent while he continued his required programs and therapy. It is undisputed that B. L. made considerable progress toward reunification with his parents and siblings. 1 B. L. turned eighteen in November 2020. 3 As his eighteenth birthday approached in 2020, B. L. had progressed such that the juvenile court was preparing to discharge him from probation. However, Iowa Code section 232 . 147(4) (2020)2 states: Official juvenile court records containing a petition or complaint alleging the commission of a delinquent act that would be a forcible felony if committed by an adult shall be public records subject to a confidentiality order under section 232 . 149A or sealing under section 232.150. However, such official records shall not be available to the public or any governmental agency through the internet or in an electronic customized data report unless the child has been adjudicated delinquent in the matter. Iowa Code section 232.150 provides that the court shall set a hearing to seal the records two years after the date of the last official action. For B. L. , this meant his records would not be sealed before 2023. In 2021, the court held a hearing to review B. L.’s case and progress and address the motion. At the hearing, B. L. asked the court to find Iowa Code section 232.147 unconstitutional as cruel and unusual punishment under the Iowa and United States Constitutions.3 Once the information was made public , he asserted, it would be easily found on the internet by anyone with access—anyone could easily take a screenshot and preserve that photograph beyond the two-year span even if his records were sealed. And, the State’s recommendation that B. L. not be 2 Between the time B. L. was adjudicated a delinquent in 2017 and filed the motion in 2020 , no substantive changes were made to the applicable cod

FAQs

What is the core issue on appeal in B.L.’s case?

Whether Iowa statutes that make certain adjudicated juvenile delinquency records public after at least two years are constitutional when applied to B.L.

Why did B.L. seek confidentiality of his juvenile records?

B.L. argued that once the records become public, they can be easily found online and preserved beyond any later sealing, undermining confidentiality goals.

What was the court’s ultimate decision?

The Iowa Court of Appeals affirmed, holding the challenged statutory scheme could not be considered cruel and unusual punishment because it was not punitive.

Aug 21, 2026

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