In a unanimous decision filed May 1, 2026, the Iowa Supreme Court affirmed the constitutionality of Iowa Code § 80F.1(25), a statute granting law enforcement officers the right to seek judicial review when placed on a prosecutor’s Brady‑Giglio list—a roster of officers whose past conduct may raise credibility concerns in criminal cases.

The ruling came in Richmond v. Jefferson County Attorney, a case involving Jefferson County Sheriff Bart Richmond, who petitioned the courts after being placed on the county attorney’s Brady‑Giglio list following a 2024 use‑of‑force incident involving one of his deputies. The district court ordered his removal from the list, and the county attorney appealed, arguing the statute violated due process obligations and the separation of powers.

Justice McDermott, writing for the full court, held that the law does not interfere with prosecutors’ constitutional duty to disclose impeachment or exculpatory evidence. The statute regulates only the maintenance of the Brady‑Giglio list itself—not what prosecutors must disclose in individual criminal cases. Prosecutors remain fully obligated to turn over any required evidence, regardless of whether an officer is on or off the list.

The court also rejected the argument that judicial review intrudes on core prosecutorial functions. The justices concluded that allowing a judge to review whether an officer belongs on a list does not dictate charging decisions, trial strategy, or evidence disclosure, and therefore does not violate the separation‑of‑powers doctrine.

The dispute stemmed from an April 2024 OWI arrest in Fairfield, where body‑camera footage showed a sheriff’s deputy forcefully pushing a handcuffed passenger’s head onto a vehicle trunk during an argument. After reviewing the footage and raising concerns about the sheriff’s handling of the internal investigation, the Jefferson County Attorney placed Sheriff Richmond on the Brady‑Giglio list, citing concerns about his judgment, credibility, and candor.

Richmond sought reconsideration and, after being denied, petitioned for judicial review under § 80F.1(25). The district court found that while Richmond’s actions were not fully transparent, they did not amount to dishonesty. The Iowa Supreme Court agreed, affirming the order to remove his name from the list.

The ruling solidifies Iowa’s framework for balancing officer rights with prosecutorial obligations. By upholding judicial review, the court confirmed that officers have a lawful avenue to challenge their placement on credibility‑impacting lists—while prosecutors retain full authority to disclose any evidence required under Brady and Giglio.

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