Laszlo Papp, Petitioner–Appellant, v. Iowa Plumbing and Mechanical Systems Board, Respondent–Appellee. (2026)

“Laszlo to the Rescue” is how Laszlo Papp advertised his unlicensed contracting business. He now appeals the district court's order affirming a decision of the Iowa Plumbing and Mechanical Systems Board imposing a $2,000 civil penalty for violating state licensing requirements. We affirm the district court's decision.¹

After investigating a citizen complaint, the board found Papp had performed HVAC work without a license.² The board decided the violations warranted a civil penalty of $2,000.³ Papp challenged the board's decision under Iowa Code section 17A.19. He argued the board lacked personal and subject matter jurisdiction and claimed he was denied his Seventh Amendment right to a jury trial during the administrative proceedings. The district court found the board had personal and subject matter jurisdiction over Papp and that he was not entitled to a jury trial. On appeal to this court, Papp raises the same claims.⁴

We start with jurisdiction. “The subject matter jurisdiction of an administrative agency is authority conferred by statute.” MC Holdings, L.L.C. v. Davis Cnty. Bd. of Rev., 830 N.W.2d 325, 329 (Iowa 2013). The board had jurisdiction to impose a civil penalty under Iowa Code section 105.27. As for personal jurisdiction, “the exercise of in personam jurisdiction over parties by [state agencies] is not immune from Fourteenth Amendment due process scrutiny.” Covia v. Robinson, 507 N.W.2d 411, 415 (Iowa 1993). But as the State explains, Papp was operating his business in the Fairfield area, “comfortably within the confines of personal jurisdiction under Iowa law.” And as the district court said, “Papp makes a series of fanciful legal arguments to attack jurisdiction.” Because we agree with the district court that Papp's legal arguments “do not hold water,” we affirm that the board had jurisdiction over Papp and the complaint against him.

The district court also denied Papp's claim that his jury trial right under the Seventh Amendment was violated. The court's conclusion that “the board's actions were not unconstitutional, as Papp did not have a right to a jury trial in these administrative proceedings” is correct and requires no further analysis on our part.

We affirm by memorandum opinion. See Iowa R. App. P. 21.26(1)(d), (e).

AFFIRMED.

FOOTNOTES

1.   We review rulings on subject matter jurisdiction for correction of errors at law. Keokuk Cnty. v. H.B., 593 N.W.2d 118, 122 (Iowa 1999). We review constitutional issues raised in agency proceedings de novo. ABC Disposal Sys., Inc. v. Dep't of Nat. Res., 681 N.W.2d 596, 605 (Iowa 2004).

2.   “HVAC” means “heating, ventilation, air conditioning, ducted systems, or any type of refrigeration used for food processing or preservation.” Iowa Code § 105.2 (2024).

3.   The Board cited Iowa Code section 105.10(1), (2), .19, .22(9) and Iowa Administrative Code 641-32.2(37), 32.5(1)(a), (c), (d), (h) (renumbered as Administrative Code 481-434.2(37), 434.5(1)(a), (c), (d), (h) effective Apr. 2, 2025).

4.   Papp also raises two new issues. We do not address those new issues because they are unpreserved. “We have held a party preserves error on an issue before an agency if a party raises the issue in the agency proceeding before the agency issues a final decision and both sides have had an opportunity to address the issue.” Staff Mgmt. v. Jimenez, 839 N.W.2d 640, 647 (Iowa 2013).

Opinion by Tabor, C.J.