UPDATES & ANALYSIS

December 2025 Opinion Roundup

by Matt McGuire | March 3, 2026

The Iowa Supreme Court entered opinions in eight cases in December 2025. At the links immediately below, you can read On Brief’s analysis of the following opinions:

• City of Davenport v. Office of Author of the State of Iowa, No. 24-1160, concerning whether the State Auditor may use in-house counsel to represent him in connection with an appeal regarding access to Davenport city records;
• Kelchner v. CRST Expedited, Inc., No. 24-0607, regarding whether a foreign corporation consents to jurisdiction in Iowa by registering to do business within the state; and
• State v. Lindaman, No. 24-0769, regarding whether allowing testimony by minors in criminal trials via ne-way closed-circuit video violates a defendants’ right to confront their accusers under the Iowa Constitution.

The remaining opinions from December are summarized below.

Oscar Recio et al. v. Frederick M. Fridley et al., No. 23-0990
Opinion date: December 5, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether the district court correctly acted as finder of fact when considering motion to enforce a settlement agreement reached by the plaintiffs’ prior attorney.
• Whether substantial evidence supported the district court’s finding that the attorney had authority to settle the personal injury claim on his clients’ behalf.

Oscar Recio, an over-the-road trucker, was injured while making repairs underneath his parked semi-truck when Frederick Fridley crashed into it after becoming distracted by his cellphone. Recio retained a Texas attorney, Cesar Palma, to represent him. Without Recio’s knowledge, Palma negotiated a $125,000 settlement with the defendants’ insurer, but Recio never signed the release. Recio later hired new counsel and filed suit in Iowa, and the defendants moved to enforce the settlement. The district court, acting as factfinder, found that Recio failed to rebut the presumption that his attorney had authority to settle, and the Court of Appeals affirmed.

The Supreme Court affirmed the decision of the Court of Appeals and the district court judgment enforcing the settlement, holding that substantial evidence supported the finding that Palma had authority to settle the case. The Court reasoned that under Iowa law, attorneys are presumed to act with authority when settling cases on behalf of their clients, and rebutting this presumption requires clear and satisfactory proof. Because the district court acted as factfinder without objection from either party, its factual findings were binding on appeal if supported by substantial evidence.

The Court explained that Oscar’s affidavit—asserting that Palma never informed him of settlement negotiations—failed to show that Oscar ever restricted Palma’s negotiating authority when hiring him. Email correspondence indicated that Palma had communicated with his client, and that Recio’s offered no corroborating evidence from Palma, no ethics complaint, and no testimony rebutting Palma’s presumed authority. The Court concluded that a reasonable mind could accept this evidence as adequate to find that Oscar failed to rebut the presumption. The Court also held that Recio waived any procedural challenge by failing to object when the matter was submitted to the district court as factfinder. Justice Waterman authored the opinion of the Court, in which all justices joined except Justice Oxley, who dissented.

In dissent, Justice Oxley argued that Recio’s affidavit created a genuine issue of material fact regarding Palma’s authority that should have precluded summary enforcement, and that the defendants’ motion should have been treated as a summary judgment proceeding rather than a bench trial.

In re the Marriage of Matthew Kraus and Molly Kraus, No. 23-2069
Opinion date: December 12, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether Iowa Rule of Civil Procedure 1.413 authorizes dismissal of a petition as a sanction for filing the petition in violation of the rule.

Matthew and Molly Kraus divorced in November 2022 under a stipulated decree addressing custody, care, and visitation of their two children. Only fifty-one days after entry of the decree, Matthew filed a petition to modify the custody, care, and visitation arrangement. During discovery, Matthew admitted in his deposition that nothing had changed since the decree and that the petition was his “attempt to fix the things that [he] regret[ted] about the divorce decree.” Molly moved for sanctions under Rule 1.413, which requires that pleadings be well grounded in fact and not filed for improper purposes. The district court found the petition violated Rule 1.413, dismissed the petition as a sanction, and ordered Matthew to pay Molly’s attorney fees of $7,226.65. The Court of Appeals affirmed the finding of a Rule 1.413 violation and the attorney fee award, but reversed the dismissal sanction.

The Supreme Court affirmed the Court of Appeals, holding that Rule 1.413 does not authorize dismissal as a sanction for violating the rule. The Court affirmed the district court’s finding that Matthew’s petition violated Rule 1.413 and that the monetary sanction was appropriate. The Court reasoned that while Rule 1.413 requires imposition of an “appropriate sanction” when a pleading is signed in violation of the rule, it does not define or limit what constitutes an appropriate sanction. The Court noted that an order to pay reasonable expenses is only one nonexclusive example of an appropriate sanction. However, the Court rejected the argument that Rule 1.413 provides an independent basis for dismissal. The Court observed that Iowa Rule of Civil Procedure 1.517(2)(b)(3), governing discovery violations, explicitly authorizes dismissal, implying that the absence of such language in Rule 1.413 was intentional. Justice McDonald authored the opinion of a unanimous Court.

In re the Marriage of Jason C. Owen and Alison A. Brinker, No. 24-0830
Opinion date: December 12, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether the court of appeals erred in modifying the dissolution decree to include an award of traditional spousal support.

Jason Owen and Alison Brinker married in 2003 and accumulated significant assets during their nineteen-year marriage, including Jason’s business, Accu-Steel, which designs and manufactures fabric-covered steel-framed buildings. Alison, a certified public accountant who let her license lapse while working for Accu-Steel, sought a $13,500 monthly award of traditional spousal support in their 2022 divorce proceeding. The district court awarded Jason property valued at approximately $7.5 million, including Accu-Steel, and awarded Alison property valued at approximately $1.4 million plus a cash equalization payment of over $3 million. The district court denied spousal support, concluding that Alison could earn $69,000 annually through employment plus approximately $212,000 annually from investing the equalization payment at a 7% return, giving her sufficient income to maintain her predivorce lifestyle. The Court of Appeals modified the decree to award Alison $3,500 monthly in spousal support, finding the gap in the parties’ incomes difficult to reconcile without such an award.

The Court affirmed the Court of Appeals’ decision regarding the valuation of Accu-Steel but vacated its modification to include a spousal support award, thereby affirming the district court’s dissolution decree denying spousal support. The Court reasoned that traditional spousal support is intended to allow the receiving spouse to maintain the lifestyle enjoyed during the marriage, not to equalize the parties’ incomes. When a spouse receives sufficient assets in the property division to generate income that meets their needs, an award of traditional spousal support is unneeded. The Court explained that using Jason’s future income potential from Accu-Steel to justify spousal support was improper because that potential was already accounted for in the business valuation and property division. Awarding spousal support based on the same income potential would constitute a duplicative award. The Court found that even using Alison’s “fully loaded” expense estimate, her estimated income of $281,269 annually exceeded her needs, leaving an annual surplus of approximately $59,000. The Court also noted that the court of appeals improperly provided Alison a “buffer for poor market years” while Jason bore all the risks of operating the business. Justice Oxley authored the opinion of the Court, in which all participating justices joined. Chief Justice Christensen did not participate in the consideration or decision of the case.

Iowa Northern Railway Company v. Floyd County Board of Supervisors et al., No. 24-0509
Opinion date: December 19, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether federal railroad law under the Interstate Commerce Commission Termination Act of 1995 preempts state drainage law that authorizes a drainage district to require a railroad to install a culvert through a railroad embankment.

A joint drainage district sought to replace an aging stone culvert beneath Iowa Northern Railway Company’s embankment near Nora Springs with a new 5.5-foot diameter steel pipe culvert using the “jack and bore” construction method. The existing culvert, built more than a century ago, was in poor condition. Iowa Northern sued to stop the project, arguing that federal railroad law under the Interstate Commerce Commission Termination Act preempted the state drainage district’s authority to compel the installation. The district court agreed with Iowa Northern and issued a writ of mandamus prohibiting the project, and the Court of Appeals affirmed.

The Supreme Court vacated the Court of Appeals opinion, reversed the district court judgment, and remanded for entry of judgment in favor of the drainage district and dissolution of the writ of mandamus.

The Court reasoned that the Interstate Commerce Commission Termination Act does not categorically preempt Iowa’s drainage laws because requiring a railroad to install a drainage pipe does not subject the railroad to a permitting requirement that denies it the opportunity to operate, nor does the federal Surface Transportation Board directly regulate the construction of drainage pipes beneath rail lines.

The Court then concluded that the project would have only incidental effects on rail transportation insufficient to trigger preemption. The evidence showed that the jack-and-bore method is the industry standard, with one contractor testifying to approximately 6,500 successful installations—mostly under rail lines—without incident. The Court found that Iowa Northern’s safety concerns “unnecessarily catastrophize what the evidence suggests is a rather common construction practice.” The Court further held that a railroad cannot manufacture a preemption claim by voluntarily choosing to halt operations during a proposed construction project that can be performed safely. Justice McDermott authored the opinion of a unanimous Court.

Alex Butter et al. v. Midwest Property Management IC, LLC et al., No. 24-1752
Opinion date: December 31, 2025
On appeal from the Iowa District Court for Johnson County

Issues:

• Whether the district court erred in finding only four instances of trespass when the landlord showed the rental unit to prospective tenants.
• Whether the district court applied the correct measure of damages for the trespasses.
• Whether Iowa Code section 562A.12(8) authorizes an award of attorney fees in a common law trespass action.

Alex Butter and Sydney Stodola rented a duplex in Iowa City from Midwest Property Management (KMB) and Ruby Investments. Shortly after moving in, KMB began frequently showing the unit to prospective tenants for the next rental period. The parties’ leasing agreement provided KMB the right, subject to the tenants’ consent, to enter the unit to show the unit, with 24 hours notice.

After the tenants complained about the frequency and unpredictability of showings, KMB sent an email establishing a schedule for showings on certain days and times. Despite this schedule, KMB sometimes requested showings outside those hours. The tenants permitted entry when KMB provided the required twenty-four-hour notice under the lease but refused entry on four occasions when KMB arrived without prior notice. The tenants sued in small claims court for common law trespass, requesting $250 per trespass and attorney fees. The magistrate found four trespasses occurred and awarded damages equal to three days’ rent. The district court largely affirmed but modified the damages calculation to award three-and-a-half days’ rent, totaling $147. The district court declined to award attorney fees.

The Supreme Court affirmed. The Court reasoned that implied consent to enter depends on whether the tenants’ conduct reasonably led the landlord to believe it had authority to enter, not on whether the tenants subjectively knew they could withhold consent. The evidence showed that the tenants routinely allowed KMB to enter when twenty-four-hour notice was provided, even outside the scheduled timeframe, which supported a finding of implied consent for those entries. The tenants demonstrated they understood they could refuse entry without notice because they did refuse entry on four occasions. Regarding damages, the Court found that the district court’s award based on daily rental value had a reasonable basis in the record and cited the Restatement (Second) of Torts, which provides that a party deprived of possession is entitled to recover at least the rental value for the period of deprivation.

Regarding attorney fees, the Court held that Iowa Code section 562A.12(8) applies only to rental deposit disputes, not to all actions involving a rental agreement. Chief Justice Christensen authored the opinion of a unanimous Court.

Tags: Iowa Supreme Court 2025-26