In AFSCME Iowa Council v. State, 484 N.W.2d 390 (Iowa 1992), unions representing public employees brought an action to enforce an arbitration award granting wage increases to government employees. The question, as framed by the court, was "can the government be made to perform in accordance with its contracts, or is the other party, by reason of constitutional and statutory rules intended to protect the public treasury, left to the vagaries of the political process?" Id. at 391. The court stated that "we think the State can indeed be required to comply." Id. The Iowa Supreme Court in AFSCME/Iowa Council based its holding on the theory that when a government enters into a contract with an individual, it implicitly appropriates the money to satisfy a debt as a result of the contract. Id. at 394. The court did not discuss how, as a practical matter, it would enforce an order directing the legislature to make an appropriation. It merely stated that "the considerations, including political considerations that go into the appropriation process, are left to the legislative branch . . . . The judicial branch will intercede . . . in that process only when a failure to act, or a deadlock, has left an adjudicated state obligation uncollectible." Id. at 396. The Iowa Supreme Court in AFSCME/Iowa Council did not believe that such intercession would come to fruition, stating: "we trust, owing to the goodwill and respect for the rule of law on the part of the governor and the legislators, such a point will not be reached in this dispute." Id.