UPDATES & ANALYSIS

Iowa Supreme Court Upholds Immunity in Horse-Drawn Mower Injury Case

by Ryan P. Harvey | July 29, 2026

The Iowa Supreme Court affirmed the dismissal of a personal injury claim arising from an accident involving a horse-drawn sickle mower in a unanimous decision filed on June 12, 2026. In Shafer v. Santana, the Court held that a farmer operating a horse drawn sickle mower was engaged in the “domesticated animal activity” of driving under Iowa’s Domesticated Animal Activities Act, despite the fact that the horses were briefly stopped when the injury occurred. Additionally, the Court concluded that the plaintiff’s expert evidence, even taken in the light most favorable to her, did not create a genuine issue of material fact as to recklessness. This meant that the statutory immunity could not be overcome.

This case began when Frank Santana was mowing his pasture with a horse drawn sickle mower while Jenny Shafer filmed him. After Santana finished mowing, he got off the mower and asked Shafer to hold the horses while he raised the sickle bar. Shafer held one horse by its lead rope, standing on the side away from the sickle bar. When the sickle bar dropped to the ground, the noise spooked the horses. The horses moved backward, then forward, and Shafer fell. The steel wheel of the mower ran over her and dragged her several feet, leaving her paralyzed from the waist down and with medical expenses over $700,000. Shafer sued Santana for $18.2 million. The district court dismissed the suit on summary judgment, ruling that Santana was immune under the Iowa’s Domesticated Animal Activities Act. The court of appeals agreed that the Act applied but reversed on the question as to whether Shafer could raise a fact question on the issue of recklessness, which could defeat the statutory immunity. Santana sought further review.

Iowa Code section 673.2 shields an owner from liability for injuries “resulting from the inherent risks of a domesticated animal activity.” Section 673.1(3)(a) defines a domesticated animal activity to include “driving a domesticated animal.” Shafer argued that once Santana dismounted and stopped the horses to raise the sickle bar, he was no longer “driving” them, so the Act’s immunity should not apply. The Court disagreed with how the court of appeals got to its answer, even though it agreed with the answer itself. Rather than relying on a generic dictionary definition of “driving,” the Court explained that the term is one of art within the equine community and means “the activity of an individual controlling the movement of an equine harnessed to a nonmotorized vehicle, such as a carriage.” Applying that definition, the Court found that the horses remained harnessed to the mower throughout the sequence of events, so Santana was still driving them even during the brief pause to secure the sickle bar. The Court rejected Shafer’s attempt to separate the activity into discrete moments, explaining that liability should not turn on whether the horses happened to be standing still or moving at the precise instant of injury. Relying on a parade case involving a runaway pony, the Court reasoned that a domesticated animal activity has to be viewed in its entirety and not broken into isolated snapshots. Because Shafer was at minimum a spectator to that activity when she was holding the horses, the statutory immunity applied to her injuries, and the burden shifted to her to identify an exception.

The second issue was whether Shafer’s evidence of recklessness was enough to survive summary judgment. Iowa law sets a high bar for recklessness, requiring proof that the defendant intentionally performed an unreasonable act and disregarded a known or obvious risk, making harm highly probable. Reckless conduct must be an act that is an extreme departure from ordinary care rather than a mere lapse in judgment. The Court acknowledged that expert opinion can sometimes support an inference of recklessness, but only where it shows the defendant disregarded a risk that was known to him or so obvious that he must have been aware of it. Here, Santana was never deposed, leaving the record without any direct evidence as to what he actually knew about the dangers of operating the mower. Shafer’s own expert, an eighty-two-year-old horseman, claimed that the mower was rusty, the safety rod was not secured, the horses were undertrained, and no one should have stood in front of the horses to hold them. Nonetheless, the Court found these opinions described ordinary negligence instead of a conscious disregard of a known risk. The Court also emphasized that Shafer had held the horses in a similar manner earlier that same afternoon without incident, undercutting any claim that harm was highly probable. Because the Act specifically protects against unpredictable reactions by an animal to a sudden loud noise, the Court concluded that the risks here were the ordinary and inherent risks the legislature intended to immunize. Therefore, this injury was not the product of Santana’s recklessness.

The Court did not pretend this was an easy result to reach. It acknowledged that Shafer’s injuries were severe and that she would be left without a forum to pursue her claim. However, it explained that the legislature made a policy choice to protect owners of domesticated animals from liability for the unpredictable behavior those animals inevitably present, and the Court was bound to apply that choice as written. The Court vacated the court of appeals’ opinion and affirmed the district court’s dismissal of the suit.

Tags: Iowa Supreme Court 2025-26