405 F.3d 700 (8th Cir. 2005)
Iowa’s 2,000-foot residency rule is constitutional — the leading federal case upholding where-you-can-live restrictions.
Good law. Still followed. Later cases may have narrowed it — see Scope. Binds federal courts in its circuit only. Persuasive, not binding, everywhere else.
In 2002 Iowa barred people convicted of certain sex offenses against minors from living within 2,000 feet of a school or registered child care facility. A federal district court struck the law down in a class action, finding it left large parts of many towns off limits.
The Eighth Circuit reversed. The restriction did not violate substantive due process (including the rights to travel and family privacy), did not compel self-incrimination, and was not ex post facto punishment. Judge Melloy dissented on the ex post facto question. The Supreme Court declined review.
Doe v. Miller became the federal model for residency restrictions. Courts across the country cite it when upholding buffer zones around schools and child care facilities.
It decided federal claims only; Iowa’s own constitution was addressed in separate state litigation. It did not consider the practical effects later cases have weighed, such as homelessness and lost access to treatment — the reasoning behind In re Taylor in California.
Last verified against the sources above on September 30, 2026.
These are plain-language summaries of court decisions, written for general education. A ruling binds only the courts beneath the court that issued it, later decisions and new laws can change what it means, and how it applies to any one person depends on facts a summary cannot capture. Read the opinion itself, and talk to a lawyer licensed in your state before relying on any case. This page is not legal advice.