UPDATES & ANALYSIS

May 2026 Iowa Court of Appeals Published Opinion Roundup

by Rox Laird | May 22, 2026

The Iowa Court of Appeals selects certain opinions for publication in the Northwestern Reporter. In May, the Court of Appeals selected two opinions for publication. Following are summaries of those opinions.

Jay Straight and Lori Straight v. Hagie Manufacturing Co., No. 25-0326

Opinion date: March 11, 2026

On appeal from Harrison County District Court

[Disclosure: Nyemaster Goode attorneys Dana W. Hempy and Katie L. Graham represented Hagie Manufacturing in this case.]

Issue:

• Were plaintiffs’ negligence claims for damage to a chemical sprayer barred by the economic loss doctrine?

Jay and Lori Straight’s son, Jackson, was operating the family’s mechanized sprayer applying chemicals to a field when the front axle broke and the machine fell to the ground. Jackson was not injured and there was no damage to the chemical tank, although the chemicals could no longer be used.

The Straights filed suit in Harrison County District Court against the sprayer’s manufacturer, Hagie Manufacturing, claiming negligent failure to warn, manufacturing defect, design defect, and negligence. The Straights sought damages for the sprayer itself, the chemicals in the sprayer at the time, and for loss-of-use while the sprayer was being repaired.

The district court granted summary judgment in favor of Hagie on three of the Straights’ four claims, saying the economic loss doctrine barred all claims except for the Straights’ failure-to-warn claim, and it concluded the Straights could seek damages for the cost of the lost chemicals. However, the court subsequently granted Hagie’s motion to reconsider and dismissed all of the Straights’ claims.

On appeal, the Straights argued that the economic loss doctrine does not apply to their claims and instead say they can bring tort claims seeking damages for the sprayer and loss of the chemicals because the sprayer’s axle breaking was a “sudden and dangerous occurrence.” Hagie countered that the economic loss doctrine applies and Straights only have contractual remedies.

The Court of Appeals, in a three-judge panel decision written by Court of Appeals Judge Sharon Soorholtz Greer joined by Court of Appeals Judges Julie Schumacher and Mary Chicchelly, held that the district court properly granted summary judgment in Hagie’s favor.

In discussing the economic loss theory, the Court of Appeals cited the Iowa Supreme Court’s 2000 decision in Determan v. Johnson, which said that a plaintiff who has suffered only an economic loss due to the negligence of another has not been injured “in a manner which is legally cognizable or compensable.” In that case, a home purchaser sued the prior owners who built the home for damages after the purchaser discovered serious structural issues with the roof.

While the roof did not collapse as the plaintiff had feared, she sued seeking damages for the cost of repairing the roof. The Iowa Supreme Court concluded that the economic loss doctrine applied in that case because, while the defects “present a genuine safety hazard to persons and property, that risk has not come to pass,” the economic loss doctrine applied to the plaintiff’s tort claims, and her remedy was in contract law.

In the Straights’ case, the incident was not described as violent and the broken axle did not cause any personal injury or damage to property beyond the sprayer itself.

“Although the Straights, in their briefing and at oral argument, emphasize that the axle failure was a violent, sudden, and dangerous occurrence, that characterization alone is not determinative,” the Court of Appeals said.

“We instead consider not only the type of risk, but also the nature of the defect, the manner in which injury occurred, and the types of damages to be recovered,” Court of Appeals Judge Soorholtz Greer wrote. “Here, the nature of the defect claimed was improper welding and a faulty front axle, the risk involved a possibility of a malfunction or breakdown, and the damages requested were for the repair of the sprayer and its components—all related to economic losses.”

Finally, the Court disagreed with the Straights’ claim that the chemicals that remained in the sprayer tank and were no longer usable constitute “other property” damaged when the sprayer broke down. That’s because the chemicals were part of the sprayer as a fully integrated system and the chemicals in the sprayer do not constitute other property or transform the Straights’ contract claims into tort claims.

“The core function of the sprayer is to spray chemicals on fields. Without the chemicals, the sprayer would not function as intended,” Soorholtz Greer wrote. “Because the chemicals in the sprayer’s chemical tank are an integral part of the sprayer, the Straights’ claim for damages does not extend beyond the sprayer itself.”

State of Iowa v. Jeffrey Dewayne Davis, No. 24-1302

 Opinion date: Feb. 11, 2026

On appeal from Scott County District Court

Issues: Did a trial court improperly admit a domestic-abuse victim’s statements made to a prosecutor outside the courtroom; and, did the court err by adding a habitual-offender sentence enhancement without holding a separate hearing?

Jeffrey Davis was convicted after a Scott County bench trial on charges of domestic abuse assault, third or subsequent offense, assault on a peace officer, and interference with official acts resulting in bodily injury based on accusations of his girlfriend and his physical encounter with a police officer when he was arrested.

Davis argued on appeal that statements made by his girlfriend, R.H., to a county prosecutor regarding her unwillingness to testify should not have been admitted at trial. And, he challenged the district court’s habitual-offender sentencing enhancement based on his prior convictions.

The Court of Appeals affirmed the district court in part and reversed in part in a panel decision written by Court of Appeals Judge Tyler Buller, joined by Court of Appeals Judges Mary Chicchelly and Samuel Langholz.

The district court allowed R.H.’s statements to be admitted at trial after finding Davis violated a no-contact order when he was recorded in phone calls from jail encouraging R.H. not to testify. R.H. told the prosecutor she would go to jail herself rather than comply with the subpoena, and she did not appear for trial.

The Court of Appeals held that the district court properly allowed R.H.’s statements. “While a criminal defendant ordinarily has the constitutional right to confront the witnesses against him,” the Court of Appeals said, “he forfeits that right when he engages in wrongdoing intended to prevent the witness from testifying at trial.”

“We have listened to the recorded jail calls ourselves, as well as the district court’s summary of them, and we have little trouble concluding the State met its burden here,” Court of Appeals Judge Buller wrote. “As the district court put it, the three submitted recordings involved Davis ‘clearly’ trying to ‘persuade, cajole, sweet talk the complaining witness into not testifying.’”

The Court of Appeals panel, however, disagreed with the district court’s handling of the recidivist enhancement of Davis’ sentence. Initially, the district court told the parties it planned to hear the State’s evidence on Davis’ prior convictions in a separate proceeding at the conclusion of the trial for enhancement purposes if the defendant were found guilty. The second phase of the bifurcated trial did not happen, however, as the trial court determined there was sufficient evidence of prior convictions.

The Iowa Supreme Court has found that failure to comply with the bifurcated-trial process under the Iowa Rules of Criminal Procedure requires reversal and remand to afford the State the opportunity to prove the enhancement following the proper procedure. Thus, the Court of Appeals vacated Davis’ recidivist enhancement and remanded the case for further proceedings in which the trial court can afford the State and Davis the bifurcated-trial proceeding, or Davis can engage in a proper colloquy and stipulate to the prior co

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