UPDATES & ANALYSIS

7.25

January 2025 Opinion Roundup

by Emma Sillman | July 25, 2025

The Iowa Supreme Court entered opinions in eleven cases in January 2025. At the links immediately below, you can read Rox Laird’s analysis of the following opinions:

Lance Allen Degeneffe v. Home Pride Contractors, Inc. , concerning whether a contractor who granted a 30-day grace period with a 1.5% interest for tardy payment was subject to the Iowa Consumer Credit Code;

The remaining opinions from December are summarized below.

 

State of Iowa v. Alison Elaine Dorsey, No. 23-1063

Opinion date: January 10, 2025 (Amended March 25, 2025)

On further review from the Iowa Court of Appeals

Issue:

• Whether the district court abused its discretion in granting the State’s motion to move venue after a mistrial.

Alison Dorsey was charged with first-degree murder and child endangerment resulting in death after an eleven-week-old baby died at her daycare.  Dorsey was tried in Cass County where she lived and the events took place.  The district court declared a mistrial after the jury voted ten to two to acquit Dorsey.  The State filed a motion to change venue to a different county claiming it could not receive a fair trial in Cass County based on the court’s experience selecting a jury for the first trial and a social media campaign by community members.  The district court granted the motion and moved venue for Dorsey’s second trial to Pottawattamie County.  In the second trial, Dorsey was convicted of the lesser included offense of second-degree murder and child endangerment resulting in death.  Dorsey appealed on several grounds including the transfer of venue out of Cass County.  The Iowa Court of Appeals affirmed Dorsey’s convictions.  Dorsey sought further review to examine whether the change of venue as requested by the State was appropriate.

The Iowa Supreme Court affirmed in part and vacated in part the decision of the Court of Appeals, reversed the district court judgement, and remanded the case for a new trial.  The Court agreed with Dorsey’s argument that the district court prematurely granted the State’s motion for change of venue.  The Court noted that the parties were able to successfully seat an impartial jury for the first trial in a day and a half.  The Court found no reason why the district court could not attempt to use the same voir dire process for the second trial before ruling on the motion to transfer.  The Court also found the evidence presented by the State concerning the media campaign—including newspaper articles, church bulletins, and Facebook posts—failed to amount to “pervasive and inflammatory” publicity required to support a change of venue.  Justice Oxley authored the opinion of the Court and Justices Waterman, Mansfield, and McDermott joined.  Chief Justice Christensen took no part in the decision.

Justice Waterman authored a concurrence in which Justice Mansfield joined.  Justice Waterman focused on Dorsey’s statutory right to be tried in her home county where the alleged crime occurred and emphasized that this right strongly disfavored transfer to another county.  Justice McDonald authored a dissent, in which Justice May joined, arguing that in the absence of evidence demonstrating Dorsey suffered prejudice by being tried in a different county, her convictions should be affirmed.  Justice McDonald argued the district court had considerable discretion to rule on a motion to change venue regardless of which party made the motion.

 

Marabelle Ann Abbas, et al. v. Franklin County Board of Supervisors, No. 23-0958

Opinion date: January 17, 2025

On further review from the Iowa Court of Appeals

Issues:

• Whether plaintiffs are entitled to right-of-way and/or severance damages related to the deepening and widening of a drainage ditch.
• Whether a plaintiff must convey title of a parcel of land for which the plaintiff received damages related to the drainage ditch project.

In 1906, the Franklin County Board of Supervisors (the Board) established Morgan Township Drainage District No. 1 (DD1) and excavated an existing natural land depression into a five-mile-long open drainage ditch.  The Franklin County auditor distributed notices to landowners affected project to file damages claims for the takings required to construct the ditch.  The Board award damages to fourteen landowners affected by the construction of the ditch.

In 1915, landowners in DD1 petitioned to create a new drainage district.  Improvements were made to the ditch in accordance with the request, and the district was renamed DD48.  Between 1917 and 1930, landowners partially filled the ditch and by 1937 farmers were using the land to plant crops.  In 1990, DD48 performed repairs which widened the drainage ditch, and damages related to the construction project were litigated.

The 1990 repairs proved to be ineffective, and, in 2017, the Board decided to reconstruct an open ditch similar to the one constructed in 1906.   The 2017 open-ditch, like the 1906 ditch, was impassible for farm equipment and required the adjoining land to be farmed in smaller, less efficient fields than had been possible since the 1930s.  The plaintiffs in this case were three sets of individuals—Abbas, Hanson, and Reid-Meyer—who own tracts of land involved affected by the 2017 reconstruction of the ditch.  The Board appointed an appraisal committee to assess damage claims asserted by affected landowners including the plaintiffs.  The committee limited damages assessment to the land occupied by the expanded ditch beyond what the drainage ditch historically had a right to.  The appraisal committee denied severance damages—which compensate a property owner for any decrease in value of the owner’s remaining property caused by having a drainage ditch run through it—for the Abbas and Hanson properties.  The committee did recommend severance damages for Reid-Meyer but only for a 4.01-acre parcel that became landlocked by the ditch and was no longer accessible.  The committee allowed right-of-way damages for each plaintiff based on the value of land each plaintiff lost for the construction of the ditch.  The Board approved and adopted the committee’s recommendations.  The plaintiffs appealed to the district court.

The district court concluded the plaintiffs were entitled to additional damages.  The court agreed that the plaintiffs were only entitled to right-of-way damages for the area covered by the reconstructed ditch beyond its original border.  However, the district court concluded the plaintiffs were entitled to severance damages for the reduction in value of their land.  The district court also directed plaintiff Reid-Meyer to convey warranty deed of the severed 4.01-acre parcel.  Both parties appealed.  The Iowa Court of Appeals affirmed the district court’s conclusion that plaintiffs were entitled to both right-of-way and severance damages but vacated the district court’s conveyance order, remanding for additional proceedings.

The Iowa Supreme Court affirmed in part and vacated in part the decision of the Court of Appeals and reversed the district court’s order, remanding for entry of a damages award consistent with the committee’s award.  The Court addressed three issues on appeal: whether DD48 had an easement on the plaintiff’s property prior to 2017; whether the plaintiffs were entitled to severance damages; and whether Reid-Meyer was required to convey title to the 4.01-acre parcel to DD48 based on the severance payment.  The Court rejected plaintiffs’ argument that DD48 abandoned the original 1906 drainage ditch, and concluded the plaintiffs were only entitled to right-of-way damages to the extent that the 2017 open ditch construction expanded beyond its original boundaries.  The Court determined the plaintiffs, with the exception of Reid-Meyer, were not entitled to severance damages.  The Court reasoned that DD1 was not abandoned, and the compensation paid to the original owners to compensate for the 1906 ditch construction was conclusively presumed to have included the diminution in value of the landowner’s remaining property caused by construction of the open ditch.  The Court allowed an exception for the 4.01-acre tract of land owned by Reid-Meyer.  The parcel was not landlocked in 1906, so the 2017 construction was a new severance of that parcel.  The court concluded the district court erred by awarding the plaintiffs any severance damages based on the diminution in value of their remaining land besides the 4.01-acre parcel.  The Court also held the Board was not entitled to conveyance of the severed Reid-Meyer property even if the damages award compensated the landowner for the full value of the affected property.  Justice Oxley authored the opinion of a unanimous Court.

 

State of Iowa v. Isaiah Duffield, No. 23-0786

Opinion date: January 17, 2025

On further review from the Iowa Court of Appeals

Issue:

• Whether the court of appeals erred in remanding a case to the district court only to resolve the issue of consecutive sentencing.

Isaiah Duffield was required to register as a sex offender after a juvenile conviction for third degree sexual abuse.  Duffield and the State waived reporting of the sentencing hearing.  The district court sentenced Duffield to a term of incarceration not to exceed two years and a fine of $1,025.  The district court’s written reasons for the sentence were, in full, “nature of the offense,” “plea agreement”, and “prior record.”  The district court ordered the sentence to be served consecutively with another sentence in a separate sexual abuse case.

On appeal, Duffield argued the district court abused its discretion in imposing the $1,025 and erred in failing to state its reasons for imposing consecutive sentences.  The Iowa Court of Appeals held the district court did not abuse its discretion in imposing the $1,025 fine.  However, the Court of Appeals vacated the imposition of consecutive sentences and remanded the case to a different judge only to decide whether Duffield’s sentence was to be tried consecutively or concurrently.  Duffield sought further review.

The Iowa Supreme Court only addressed the consecutive sentencing issue and vacated the sentence and the decision of the Court of Appeals.  The Supreme Court reasoned that the district court must articulate its reasons for imposing a sentence including when it imposes consecutive sentences.  The Court determined that the Court of Appeals erred in its decision to remand only on the issue of consecutive sentences to a different judge.  The Court noted that, in cases involving a failure to articulate the reason for a sentence, Iowa courts have typically vacated a defendant’s entire sentence and remanded the case for a plenary sentencing hearing.  The Court also noted that sentencing before a different judge was not required as such a process is generally only required where the sentencing was tainted and a different judge must conduct the sentencing to remove the taint.  Justice McDonald authored the opinion of a unanimous Court.

 

State of Iowa v. Lukouxs Brown, No. 23-1188

Opinion date: January 17, 2025

On further review from the Iowa Court of Appeals

Issues:

• Whether the Supreme Court’s 2010 opinion in State v. Lyman proscribing de novo review of competency determinations should be overruled.
• Whether the district court erred in allowing the State to obtain a separate psychiatric evaluation of the defendant prior to concluding the dispositional hearing required by Iowa Code 812.8(4).

Lukouxs Brown was charged with first-degree murder.  The district court found Brown was incompetent to stand trial and ordered he undergo mental health treatment with the hope he would eventually become competent to stand trial.  After several months, Brown’s treatment provider concluded Brown was still incompetent to stand trial.  Ten days after receiving the notice, the district court started a dispositional hearing as required under Iowa Code § 812.8(4).  The district court granted the State an indefinite continuance to obtain a separate psychiatric evaluation of Brown.  Several months later, after Brown moved to dismiss the case, the district court held a hearing in which the State called their own medical expert to testify.  The State’s expert concluded Brown was competent to stand trial, and the district court ordered the criminal proceedings reinstated.  Brown filed an application for interlocutory appeal.

On appeal, Brown argued the district court erred in finding him restored to competency, allowing the state to get its own psychiatric evaluation, and failing to hold a hearing within fourteen days of receiving the report concerning Brown’s competency.  On de novo review, the Iowa Court of Appeals found Brown was not competent to stand trial, and reversed the ruling of the district court ordering Brown receive more treatment.  The State sought further review.

The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court order, and remanded the case for further proceedings pursuant to Iowa Code § 812.9(3).  The Court addressed the standard of review of competency determinations and evaluated whether the district court erred in allowing the State to obtain a separate psychiatric evaluation.  The Court reaffirmed use of the de novo standard articulated in Lyman when reviewing a district court’s decision concerning a defendant’s competency to stand trial.  The Court refused to return to the errors at law standard previously used as the State had requested.

The Court also held that the language of Iowa Code § 812.8 did not authorize either party to hire an independent expert to perform a separate psychiatric evaluation after the district court receives notice from the treatment provider regarding the defendant’s competency.  The Court reasoned that chapter 812 sets forth a step-by-step process for raising, regulating, and resolving issues regarding the defendant’s competency to stand trial.  The Code explicitly allowed the parties to obtain a separate evaluation at time there was probable cause to believe Brown was incompetent to stand trial.  However, there was no such provision for the dispositional hearing after Brown’s competency had already been evaluated.  The Court also noted that allowing a separate psychiatric evaluation at that stage would go against the structure and purpose of the statute.  The statute was written to ensure evaluation is performed by a neutral physician in a timely manner.  Justice McDonald authored the opinion of a unanimous Court.

 

MIMG CLXXII Retreat on 6th, LLC v. Mackenzie Miller, No. 23-0670

Opinion date: January 24, 2025

On appeal from the Iowa District Court for Linn County

Issue:

• Whether the Federal CARES Act created a permanent requirement for landlords to give thirty-days notice prior to requiring a tenant to vacate their dwelling.

In June 2022, Mackenzie Miller entered a one-year residential lease for an apartment in MIMG CLXXII Retreat on 6th (The Retreat).  The lease provided that if the tenant failed to pay rent when due, the landlord would issue a three-day notice to pay rent.  If the rent was not paid during the three-day period, the landlord would terminate the tenancy and could pursue all remedies including filing a forcible entry and detainer (FED) action.  This three-day notice process aligned with Iowa law.

On December 7th 2022, The Retreat served Miller a notice indicating she had not paid her rent and her lease would be terminated if the rent was not paid in three days.  After nine days, Miller had not paid the rent, and the Retreat filed an FED action.  The small claims court heard The Retreat’s FED action, but declined to enter an eviction order.  The court dismissed the action reasoning that the Federal Coronavirus Aid, Relief, and Economic Security Act (CARES) Act required The Retreat to provide a thirty-day notice prior to bringing an FED action.  The Retreat appealed to the district court which affirmed the decision of the small claims court.  The Retreat sought further review.  Iowa Legal Aid appeared as an amicus curiae to argue in support of the judgement of the small claims court.

The Iowa Supreme Court reversed the judgement below and remanded for further proceedings.  The CARES Act placed a moratorium on eviction filings beginning on March 27, 2020.  Section (b) of 15 U.S.C. § 9058 provided that the moratorium would last 120 days during which a lessor could not make any action to recover the possession of a covered dwelling for nonpayment of rent.  Section (c)(1) provided the lessor of a covered dwelling unit could not require the tenant to vacate the dwelling until 30 days after providing the tenant with a notice to vacate, and section (c)(2) provided the lessor could not issue a notice to vacate until the expiration of the 120 days described in section (b).  The primary question at issue was whether the stipulations of section 9058(c) applied to post moratorium defaults, in other words, whether the CARES Act created a permanent thirty-day pre-eviction notice requirement.

The Court determined that section 9058(c), the thirty-day pre-eviction notice requirement, applied only to nonpayment defaults that occurred during the 120-day moratorium described in section 9058(b).  The Court had to determine whether the provisions of section 9058 were intertwined or not. The Court concluded that the provisions were intertwined, reasoning that § 9058(c)(1) when read alone wouldn’t work.  A solitary reading of the provision without section (c)(2) would mean that no notice to evict for any reason could go out during the COVID-19 moratorium.  The Court applied similar reasoning to section (b).  The Court concluded that section 9058 was to be read holistically, and thus, the pre-eviction notice requirement only applied to defaults that occurred during the 120-day moratorium rather than being a permanent rewrite of the law in an otherwise temporary legislation.  The Court also noted that the general presumption against federal preemptions of laws, especially in areas traditionally entrusted to state and local laws, favored its interpretation of section 9058.  Justice Mansfield authored the opinion of a unanimous Court.           

 

MIMG CLXXII Retreat on 6th, LLC v. Nathan Williams, No. 23-0672

Opinion date: January 24, 2025

On appeal from the Iowa District Court for Linn County

Issue:

• Whether the Federal CARES Act created a permanent requirement for landlords to give thirty-days notice prior to requiring a tenant to vacate their dwelling.

In May 2022, Nathan Williams entered into a residential lease for an apartment owned by MIMG CLXXII Retreat on 6th.  Williams was served a three-day notice to quit in December after he defaulted on his rent.  The Retreat then brought an FED action in the small claims division of the district court.  The district court magistrate concluded that a thirty-day notice was required because the Retreat qualified as a covered dwelling under CARES Act and dismissed the case.  The Retreat appealed and the district court affirmed.  For the same reasons set forth in Miller, the Iowa Supreme Court, per curiam, reversed the judgement of the district court and remanded for further proceedings consistent with Miller.

 

State of Iowa v. Tyre Dewayne Brown, No. 22-0023

Opinion date: January 24, 2025

On further review from the Iowa Court of Appeals

Issue:

• Whether officers unconstitutionally extended a traffic stop in violation of the Iowa and United States Constitutions.

Officer Dao Meunsaveng stopped a vehicle after receiving word from another officer that the vehicle’s two occupants may have been involved in a drug sale.  After the initial visit with the driver, Meusaveng returned to his vehicle to wait for back-up and communicated with back-up officers his plan to carry out a vehicle search.  Once back-up arrived, Meunsaveng returned to the vehicle and asked the driver to exit to sign his ticket.  One of the back-up officers told the driver he smelled marijuana, but the driver denied smoking marijuana.  Another officer asked Tyre Brown, the passenger, to exit the vehicle and he complied.  Once the occupants were outside the vehicle, the Meusaveng searched around the vehicle with his K-9.  After the K-9 alerted, officers searched the interior of the vehicle and found a firearm under the passenger seat.

Tyre Brown was charged with unlawful possession of a firearm under Iowa Code § 724.4(1).  Brown moved to suppress the evidence from the search, arguing the traffic stop violated his rights under the Iowa and United States Constitution because the stop was unconstitutionally extended in duration and scope.  The district court denied Brown’s motion to suppress and found him guilty.  Brown appealed challenging the denial of his motion to suppress.  The court of appeals affirmed the district court’s ruling on two grounds.  First, the shared-knowledge doctrine allowed Meusaveng to extend the stop.  Second, the court found the Meusaveng had smelled marijuana when he first went to the driver’s window, allowing him to extend the stop to investigate separate criminal activity.  Brown sought further review.

The Iowa Supreme Court affirmed the district court’s suppression ruling and the decision of the Court of Appeals.  There was no record from the suppression hearing.  Therefore, both parties filed statements of evidence.  The Court found that Meusaveng never mentioned the odor of marijuana during or immediately after his initial reactions with the driver.  Thus, the smell of marijuana could not be the basis for extending the traffic stop.  Rather, the Court relied on the shared knowledge doctrine which allows an officer to act upon knowledge received from another officer about criminal activity.  Though Meusaveng did not witness the potential drug transaction, he could act on the other officer’s reasonable suspicion and extend the traffic stop.  Justice McDermott authored the opinion of a unanimous Court.

 

Benjamin G. Trane v. State of Iowa, No. 23-1928

Opinion date: January 31, 2025 (Amended April 18, 2025)

On appeal from the Iowa District Court for Lee (South) County

Issues:

• Whether defendant’s trial counsel was ineffective for failing to move to sever a child endangerment claim for a separate trial.
• Whether defendant’s trail counsel was ineffective for failing to object the marshaling instruction for a child endangerment claim.

Benjamin Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment after police raided his private therapeutic boarding school for troubled youth.  The child endangerment count involved two boys, B.V. and A.H., placed in isolation rooms at different times.  A jury found him guilty of all counts.  In a post-conviction relief action, Trane alleged his trial counsel was ineffective for failing to move to sever the child endangerment count for separate trial and for failing to object to the marshaling instruction for the child endangerment count.  The district court rejected the severance claim, finding Trane made an informed decision to forgo a motion for severance to avoid delay.  The district court did find, however, that Trane’s trial counsel breached her duty by failing to object to the marshaling instruction.  The instruction used “and/or” in reference to the victims for each element.  Therefore, the jury found that each element was satisfied for either B.V., A.H., or both.  The court concluded the instruction allowed a nonunanimous verdict, which prejudiced Trane, and ordered a new trial on the child endangerment charge.  Trane appealed the motion for severance decision, and the State cross-appealed the jury instruction decision.

The Iowa Supreme Court affirmed the district court’s ruling rejecting Trane’s ineffective-assistance-of-counsel claim on the severance issue and reversed on the ruling granting a new trial for the child endangerment count.  The Court agreed with the district court’s finding that Trane’s trial counsel discussed severance with him, and Trane made an informed decision to forgo a motion for severance in an effort to make the proceedings go quicker.  The Court also found the marshaling instruction for the child endangerment charge misstated Iowa law by allowing a nonunanimous verdict.  The instruction allowed a guilty verdict that was not unanimous as to either victim because the jury was not required to agree that all elements were proven against one specific victim.  The Court held Trane’s trial counsel breached an essential duty by not objecting to the erroneous marshaling instruction.  However, the Court found that Trane failed to show prejudice due to the erroneous instruction.  The Court was unconvinced there would have been a different outcome had the instruction not used the “and/or” language referring to the two victims because the material allegations and defenses as to the two victims were the same.  Justice Waterman authored the opinion of a unanimous Court.

 

Principal Securities, Inc. v. Mark A. Gelbman, No. 23-0439

Opinion date: January 31, 2025

On further review from the Iowa Court of Appeals

Issues:

• Whether the limited scope of judicial review under Iowa Code chapter 679A requires confirmation of an arbitration award vacated by the district court.

Mark Gelbman worked as a financial advisor at Principal Securities Incorporated and was responsible for hundreds of client brokerage accounts.  His employment agreement provided that any dispute with Principal was subject to arbitration.   In 2020, Principal switched to a new software system which required employees to rebalance their clients’ accounts by selling assets one day and purchasing new assets later on a different day.  The new system required Gelbman to obtain consent from his client both on the day he sold assets and on the day he purchased assets. However, Gelbman only obtained consent from his clients on the day he sold assets, as was required before the system changed.  After this error was brought to Gelbman’s attention, he offered to resign, but his supervisor talked him out of resigning.  Three weeks later, Gelbman was terminated for failing to obtain the second consent from his clients.

As required by industry regulations, Principal reported Gelbman’s termination to the Financial Industry Regulatory Authority (FINRA).  In the report, Principal indicated that Gelbman was discharged for failure to adhere to the firm’s policies, was under internal review for wrongdoing, and was discharged due to allegations that accused him of violation statutes, rules, or regulations.  Based on Principal’s report, FINRA updated a program called BrokerCheck which provides background checks for financial professionals.  Gelbman’s BrokerCheck profile then stated he was discharged due to his failure to adhere to the firm’s policies and procedures regarding discretionary trading.  Gelbman initiated an arbitration hearing arguing that the information provided by Principal concerning his termination was misleading and potentially defamatory.  The sole arbitrator issued an award in Gelbman’s favor and recommended changes to Principal’s report.  Principal filed an action in district court to vacate the arbitration award on the grounds that it was not supported by substantial evidence.  The district court vacated the arbitration award concluding the information in the report was not defamatory under Iowa law.  The Iowa Court of Appeals affirmed.  Gelbman sought further review.

The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the decision of the district court, and remanded the case with directions for the district court to confirm the arbitration award in full.  The court emphasized that its ability to review arbitration awards is very limited.  The Court noted it would not correct errors of fact or law unless the arbitrator’s award violated a provision of Iowa Code § 679A.12(1).  The Court found that the district court and the Court of Appeals erred by relying on tort definitions to vacate the award, explaining the arbitrator was entitled to find the information provided by Principal was misleading under FINRA rule 1122.  The Court concluded there was substantial evidence on the record to support the arbitration award.  Justice Waterman authored the opinion of a unanimous Court, except for Justice McDonald, who did not participate.

 

In re Estate of Johnston , No. 22-1801

Opinion date: January 31, 2025

On further review from the Iowa Court of Appeals

Issue

• Whether the district court applied an incorrect legal standard when it granted a motion to dismiss.

John and Peggy Johnston married in 1980.  Throughout their marriage, they jointly owned two bank accounts, one checking and one money market, with rights of survivorship.  The couple did not attempt to distinguish what was his and what was hers, though, Peggy testified that John became more secretive about the accounts later in their marriage.  John created his will in 2017 and divided his assets amongst his three daughters from a prior marriage without including Peggy at all.  In 2018, when he died, the will was admitted to probate.  Peggy filed a notice of her election as the surviving spouse to receive her share of John’s estate.  Peggy made a claim on the estate for $94,500 asserting she was entitled to half of the funds that John transferred out of the couple’s joint account.  Specifically, she claimed half of a $70,000 certificate of deposit (CD) and half of a $40,000 CD.  It was unclear where the money for each of these CD’s came from.  The district court entered an order dismissing Peggy’s claim.  The district court concluded that Peggy was making a claim for conversion sounding in tort and had not met the legal standard.

Peggy appealed, arguing the district court applied the wrong legal standard.  The Iowa Court of Appeals agreed with Peggy’s argument and remanded the case to the district court.  The estate sought further review.

The Iowa Supreme Court affirmed the decision of the Court of Appeals, reversed the judgement of the district court, and remanded for a new trial.  The Court concluded that the legal standard for conversion sounding in tort would have been proper had Peggy been claiming John removed money from the account which he had no interest in.  However, that was not Peggy’s claim and the district court should have applied the legal standard used in cases of joint tenancy with a right of survivorship.  Under that standard, Peggy was presumptively entitled to half the joint account.  The Court concluded the district court erred in granting the motion to dismiss because Peggy presented sufficient evidence to demonstrate joint tenancy existed.  The Court reiterated that the district court should exercise caution in granting motions to dismiss.  Chief Justice Christensen authored the opinion of the Court.  Justice Mansfield authored a dissenting opinion, arguing the district court properly granted a directed verdict because Peggy failed to demonstrate John withdrew more than his proportional share of the funds.

Tags: Iowa Supreme Court 2024-25