Iowa Case Commentaries

Wrongful-Death Medical Malpractice in Iowa: Death Does Not Restart § 614.1(9)(a) When Injury and Causation Are Known Pre-Death

Date: Mar 1, 2026

Wrongful-Death Medical Malpractice in Iowa: Death Does Not Restart § 614.1(9)(a) When Injury and Causation Are Known Pre-Death 1. Introduction In Estate of Jill Cataldo by Zachary Mead, individually...

Imminence in Iowa Terroristic-Threat Prosecutions Is Context-Dependent: A Date-Certain Courtroom Threat Can Be “Imminent”

Date: Mar 1, 2026

Imminence in Iowa Terroristic-Threat Prosecutions Is Context-Dependent: A Date-Certain Courtroom Threat Can Be “Imminent” Case: State of Iowa v. Alicia Elaine Fredericksen Court: Supreme Court of...

“Illegal Act” in Iowa Code § 710.10(4) Is Not Limited to Sexual Conduct; Uniform Instruction Need Not Narrow the Intended Illegality

Date: Mar 1, 2026

“Illegal Act” in Iowa Code § 710.10(4) Is Not Limited to Sexual Conduct; Uniform Instruction Need Not Narrow the Intended Illegality Case: State of Iowa v. Rodney Dee Brown (Iowa Supreme Court, Feb....

Same-Day Separate Underage Alcohol Sales Count as “Second Violation Within Two Years” Under Iowa Code § 123.50(3)

Date: Feb 23, 2026

Same-Day Separate Underage Alcohol Sales Count as “Second Violation Within Two Years” Under Iowa Code § 123.50(3) I. Introduction Beecher Store, Inc. v. Iowa Department of Revenue Alcoholic Beverages...

Severable Exclusivity Clauses in Conditional Financing Proposals Terminate When a Key Condition Fails and the Lender Abandons the Proposed Terms; Trial Courts May Exclude the Defunct Proposal Under Iowa R. Evid. 5.403 to Prevent Contract–Fraud Confusion

Date: Feb 23, 2026

Severable Exclusivity Clauses in Conditional Financing Proposals Terminate When a Key Condition Fails and the Lender Abandons the Proposed Terms; Trial Courts May Exclude the Defunct Proposal Under...

Voluntary Manslaughter in Iowa Excludes Malice; Acquittal-First Murder Instructions Need Not Allow Post-Conviction Consideration of Provocation

Date: Feb 22, 2026

Voluntary Manslaughter in Iowa Excludes Malice; Acquittal-First Murder Instructions Need Not Allow Post-Conviction Consideration of Provocation Case: State of Iowa v. Sherral Jermaine Tolbert, Jr....

“Similar Facts and Circumstances” Includes a Caregiver’s Regulatory Role: The Reasonable-and-Prudent-Person Standard in Iowa Child-Abuse Supervision Cases

Date: Feb 15, 2026

“Similar Facts and Circumstances” Includes a Caregiver’s Regulatory Role: The Reasonable-and-Prudent-Person Standard in Iowa Child-Abuse Supervision Cases Introduction Amanda Cooke v. Iowa Department...

Iowa Code § 692A.105 Is Limited to Temporary Lodging Away from the Principal Residence (Not Change-of-Residence Prosecutions)

Date: Feb 15, 2026

Iowa Code § 692A.105 Is Limited to Temporary Lodging Away from the Principal Residence (Not Change-of-Residence Prosecutions) Case: State of Iowa v. Joshua Kelly Uranga (Iowa Sup. Ct. No. 23-1001)...

Iowa Requires Counsel for Estate Wrongful-Death Actions and Mandates Time to Cure Unauthorized Pro Se Filings

Date: Feb 8, 2026

Iowa Requires Counsel for Estate Wrongful-Death Actions and Mandates Time to Cure Unauthorized Pro Se Filings Introduction In Estate of Kara B. Tornell and Preston H. Tornell, both individually and...

Actual Knowledge of the Specific Peril Required for Co-Employee Gross Negligence Under Iowa Code § 85.20(2)

Date: Feb 8, 2026

Actual Knowledge of the Specific Peril Required for Co-Employee Gross Negligence Under Iowa Code § 85.20(2) Griffith v. Kulper, Supreme Court of Iowa (Feb. 6, 2026) I. Introduction Griffith v. Kulper...

No Contemporaneous Objection Required to Previously Undisclosed Oral Victim-Impact Statements at Sentencing

Date: Feb 1, 2026

No Contemporaneous Objection Required to Previously Undisclosed Oral Victim-Impact Statements at Sentencing I. Introduction In State of Iowa v. Malorie Lynn Hallock (Iowa Jan. 30, 2026), the Iowa...

Iowa District Courts Must Defer to Local Public Defender “Temporary Overload” Returns Absent Reason to Doubt Representations

Date: Feb 1, 2026

Iowa District Courts Must Defer to Local Public Defender “Temporary Overload” Returns Absent Reason to Doubt Representations Case: State Public Defender v. Iowa District Court for Scott County (Iowa...

Liberal Construction of Criminal Notices of Appeal: “All Adverse Rulings Therein” Reaches Noncollateral Postjudgment Sentencing Orders; No Defendant Right to Resentencing for Victim Impact Statement

Date: Feb 1, 2026

Liberal Construction of Criminal Notices of Appeal: “All Adverse Rulings Therein” Reaches Noncollateral Postjudgment Sentencing Orders; No Defendant Right to Resentencing for Victim Impact Statement...

IMTCA Two-Year Limitations Period Governs Iowa Code § 692.6 Misuse-of-Confidential-Data Claims, with “Injury” Occurring at the Time of the Violation

Date: Feb 1, 2026

IMTCA Two-Year Limitations Period Governs Iowa Code § 692.6 Misuse-of-Confidential-Data Claims, with “Injury” Occurring at the Time of the Violation I. Introduction Case: Victoria Abrahamson, Hana...

CMS Deficiency Reports and Conclusory Experts Do Not Establish “Recklessness” to Defeat Iowa’s COVID-19 Health-Care Immunity (Iowa Code § 686D.6)

Date: Jan 27, 2026

CMS Deficiency Reports and Conclusory Experts Do Not Establish “Recklessness” to Defeat Iowa’s COVID-19 Health-Care Immunity (Iowa Code § 686D.6) I. Introduction In Jacob M. Rose, individually and as...

Specific Personal Jurisdiction Over Digital Platforms Based on In‑State User Contracts, Data Collection, and Geo‑Targeted Monetization

Date: Jan 27, 2026

Specific Personal Jurisdiction Over Digital Platforms Based on In‑State User Contracts, Data Collection, and Geo‑Targeted Monetization I. Introduction In State of Iowa ex rel. Attorney General Brenna...

State v. Pagliai: Plea Bargains Cannot Confer Authority to Tax Costs in Dismissed Criminal Cases

Date: Jan 11, 2026

Ultra Vires Cost Assessments in Dismissed Criminal Cases: Plea Agreements Cannot Expand a Court’s Statutory Dispositional Authority Case State of Iowa v. Ronald Richard Pagliai Court Supreme Court of...

Public-Employee Co-Worker Gross-Negligence Claims Survive Workers’ Compensation Exclusivity, But ITCA Presentment Must Name Each Employee Defendant

Date: Jan 10, 2026

Public-Employee Co-Worker Gross-Negligence Claims Survive Workers’ Compensation Exclusivity, But ITCA Presentment Must Name Each Employee Defendant Introduction In Sara Montague, individually, and as...

Equitable Reformation of Easement Deeds to Correct Misnamed Trust Grantors and Erroneous Legal Descriptions Without Protecting Non–Bona Fide Purchasers

Date: Jan 10, 2026

Equitable Reformation of Easement Deeds to Correct Misnamed Trust Grantors and Erroneous Legal Descriptions Without Protecting Non–Bona Fide Purchasers Case: Mark Fink and Stacey Fink v. Donald...

Inquiry Notice From Prior Pleadings Bars Later Defamation Claims Despite Possible Discovery Rule

Date: Jan 10, 2026

Inquiry Notice From Prior Pleadings Bars Later Defamation Claims Despite Possible Discovery Rule Case: Linda Betz v. Rebecca Mathisen, Eric Muller, Kelly Rasmuson and Michael Wilson Court: Supreme...