Iowa Rule 1.413 Sanctions Cannot Include Dismissal: Commentary on In re the Marriage of Matthew Kraus and Molly Kraus

I. Introduction

The Iowa Supreme Court’s decision in In re the Marriage of Matthew Kraus and Molly Kraus, No. 23-2069 (Iowa Dec. 12, 2025), addresses a narrow but important procedural question: whether a district court may dismiss a case as a sanction under Iowa Rule of Civil Procedure 1.413 (Iowa’s analogue to Federal Rule of Civil Procedure 11).

The case arises from a post-dissolution modification petition filed a mere fifty-one days after the parties' decree of dissolution, and from the district court’s determination that the petition was filed in bad faith and in violation of rule 1.413. The district court imposed two sanctions: (1) dismissal of the modification petition and (2) an order that the petitioner, Matthew, pay the respondent Molly’s attorney fees.

The Iowa Court of Appeals upheld the finding of a rule 1.413 violation and the attorney-fee sanction but reversed the dismissal. The Supreme Court granted further review, but only on the limited question whether rule 1.413 itself authorizes dismissal as a sanction. Justice McDonald, writing for a unanimous court, affirms the Court of Appeals and clarifies that rule 1.413 “does not provide an independent basis for dismissal.”

In doing so, the court:

Reaffirms and strengthens its earlier precedent in K. Carr v. Hovick, 451 N.W.2d 815 (Iowa 1990), and the Court of Appeals’ extension of that rule in Buhr v. Howard County Equity, 2011 WL 1584348 (Iowa Ct. App.);
Explains the scope of permissible sanctions under rule 1.413;
Emphasizes the importance of access to courts and the exceptional nature of dismissal; and
Clarifies the relationship between rule-based sanctions and a court’s inherent authority.

This commentary explores the background of the dispute, the court’s holding, and the broader implications for Iowa civil practice, with particular attention to domestic relations litigation and sanctions practice.

II. Factual and Procedural Background

A. The Marriage, Decree, and Stipulation

Matthew and Molly Kraus married in April 2013 and have two children. In January 2021, Matthew filed a petition to dissolve the marriage. After nearly two years of litigation, the parties resolved their dissolution proceeding through a stipulation and agreement, which the district court incorporated into a decree entered on November 22, 2022.

Key terms of the stipulation included:

Joint legal custody of the children;
Physical care awarded to Molly;
Regular visitation for Matthew; and
A school-attendance provision (paragraph seven): the children would remain in the Maquoketa Valley School District through the 2022–2023 school year, after which Molly could enroll them in the West Dubuque School District, and thereafter the children would attend the school associated with Molly’s residence.

B. Matthew’s Immediate Regret and the Modification Petition

According to the opinion, Matthew quickly regretted the terms of the decree and intended to seek modification. On December 7, 2022—about two weeks after entry of the decree—the parties had a minor visitation dispute. Molly texted Matthew a screenshot of a paragraph from the stipulation related to visitation. Matthew replied, “Don’t worry, that’ll be getting changed soon,” followed by a smiley-face emoji.

On January 9, 2023, new counsel appeared for Matthew; prior counsel withdrew. Two days later, on January 12—only fifty-one days after the decree—Matthew filed a petition to modify. The petition sought to modify:

Custody, care, and visitation; and
Child and medical support.

The petition contained only very general assertions:

“[T]he current custody, care, and visitation orders are no longer in the best interest of the children”; and
“[T]he current child support and medical support orders may need adjusted.”

C. Rule 1.413 Sanctions Proceedings in the District Court

After discovery, Molly moved for sanctions under Iowa Rule of Civil Procedure 1.413. Her core contention was that Matthew’s petition had no factual basis for alleging a substantial change in circumstances in the short period between the decree and the modification filing. She characterized the petition as an improper attempt to re-litigate matters that had just been resolved by stipulation and decree.

In support, Molly relied on Matthew’s deposition, where he admitted:

There had been no change in circumstances between entry of the decree and the filing of the modification petition; and
The petition was his “attempt to fix the things that [he] regret[ted] about the divorce decree.”

At the sanctions hearing:

Matthew testified that he filed the petition because one child had allegedly threatened to bring a gun to school to get expelled, which he saw as evidence the child was dissatisfied with the school arrangement and the broader custody/visitation structure.
On cross-examination, however, Matthew repeatedly admitted that “nothing had changed” between the decree and the filing of the modification petition and that he had “no basis” to seek modification “other than [his] desire to change the terms of the decree.”

The district court explicitly found Matthew’s “gun threat” explanation not credible, in part because he had made no contemporaneous report of any such threat to anyone.

The court concluded:

The petition was signed and filed in violation of rule 1.413;
The violation was particularly egregious—“It would be difficult to imagine a stronger case for the imposition of sanctions” and only a faster filing than fifty-one days post-decree would make it more egregious; and
Sanctions were required.

The district court imposed two sanctions:

Dismissal of the petition to modify; and
Attorney fees of $7,226.65 plus interest at 7.33% per annum, payable to Molly.

D. Court of Appeals Decision

Matthew appealed. The Iowa Court of Appeals:

Affirmed the finding that the petition violated rule 1.413 (the petition had no factual support and was essentially an attempt at a “do-over” of the decree);
Affirmed the monetary sanction (attorney fees) as appropriate and supported by the evidence; but
Reversed the dismissal, holding that dismissal is not an “appropriate sanction” under rule 1.413.

E. Scope of Iowa Supreme Court Review

Molly applied for further review, asking the Iowa Supreme Court, among other things, to revisit and overrule precedent limiting rule 1.413 sanctions. The Supreme Court granted further review but exercised its discretion to address only one narrow issue:

Does Iowa Rule of Civil Procedure 1.413 itself authorize dismissal of a petition as a sanction for filing in violation of the rule?

All other aspects of the Court of Appeals decision—including the finding of a rule 1.413 violation and the validity of the attorney-fee award—stand unaltered.

III. Summary of the Opinion

The Iowa Supreme Court holds:

Rule 1.413(1) requires courts to impose an “appropriate sanction” when a pleading is signed in violation of the rule. The rule’s text does not expressly exclude dismissal as a possible sanction, and its list of possible sanctions (such as attorney fees) is nonexclusive.
However, longstanding Iowa precedent—especially K. Carr v. Hovick—squarely holds that rule 1.413 (formerly rule 80) “does not provide an independent basis for dismissal.”
The court sees no “compelling reason” to overrule that precedent, particularly when the request to do so was raised only in the application for further review and not in the merits briefing.
Dismissal is a “rare judicial act” because it deprives litigants of their day in court. Iowa sanctions practice favors using dismissal only where clearly authorized (e.g., by specific rules like rule 1.517 or by properly invoked inherent authority).
Consequently, the district court erred by relying on rule 1.413 alone to dismiss Matthew’s petition.

The Supreme Court therefore:

Affirms the Court of Appeals’ decision;
Affirms the district court’s finding that Matthew’s petition violated rule 1.413 and the imposition of attorney-fee sanctions of $7,226.65; but
Reverses the district court’s dismissal of the petition and remands for further proceedings.

The court explicitly notes that its decision does not limit other available mechanisms to dispose of a case on the merits, such as summary judgment or other procedural tools; it merely holds that rule 1.413, by itself, is not a dismissal vehicle.

IV. Detailed Analysis

A. The Legal Framework: Iowa Rule of Civil Procedure 1.413

Rule 1.413(1) provides that the signature of counsel (or an unrepresented party) on a motion, pleading, or other paper serves as a certification that:

The signer has read the document;
To the best of the signer’s knowledge, information, and belief, formed after reasonable inquiry, the pleading is well-grounded in fact and (via cross-reference to the rule) warranted by existing law or a good-faith argument for changing the law; and
The document is not interposed for any improper purpose, “such as to harass or cause an unnecessary delay or needless increase in the cost of litigation.”

If a pleading is signed in violation of the rule, the court must impose some “appropriate sanction” on the signer, the represented party, or both. The rule provides that:

“[T]he sanction may include an order to pay the other party . . . the amount of the reasonable expenses incurred because of the filing of the . . . pleading . . . including a reasonable attorney fee.”

The phrase “may include” introduces a nonrestrictive provision. Grammatically, the rule gives attorney fees as an example of an appropriate sanction, not as an exclusive list. The Supreme Court itself highlights the nonrestrictive nature of the clause, citing federal and style-manual authority to show that such a clause does not limit “appropriate sanction” to monetary remedies.

On a purely textual level, therefore, “appropriate sanction” is broad enough to encompass a wide spectrum of responses, potentially including non-monetary sanctions—at least in the abstract. The court then turns to the crucial question: within this broad textual universe, are terminating sanctions like dismissal allowed?

B. Precedents and Authorities Cited

1. Dupaco Community Credit Union v. Iowa District Court & Weigel v. Weigel

The court cites Dupaco Community Credit Union v. Iowa District Court, 13 N.W.3d 580 (Iowa 2024), which in turn cited Weigel v. Weigel, 467 N.W.2d 277 (Iowa 1991), to reiterate the three-part certification imposed by rule 1.413: reading the pleading, conducting reasonable inquiry, and acting without improper motive. This underscores that Matthew’s modification petition—filed almost immediately after the decree, with no actual change in circumstances—falls squarely within the kind of abusive practice rule 1.413 targets.

2. K. Carr v. Hovick (Iowa 1990)

K. Carr v. Hovick, 451 N.W.2d 815 (Iowa 1990), is the cornerstone precedent. In that case, the Iowa Supreme Court:

Addressed then-rule 80, the predecessor to rule 1.413;
“Summarily rejected” the argument that the rule could serve as a basis for dismissing a case; and
Held that the rule “provides sanctions for the filing of frivolous suits, but it does not provide an independent basis for dismissal.”

Two key points follow from K. Carr:

Rule 1.413 is a sanctioning mechanism directed at improper filings; it is not a cause of action or a separate vehicle to terminate litigation.
Other existing doctrines and rules (e.g., summary judgment, failure to state a claim, discovery sanctions under rule 1.517, inherent authority) remain available to dispose of a case; rule 1.413 does not add an extra, free-standing dismissal power.

3. Buhr v. Howard County Equity (Iowa Ct. App. 2011)

In Buhr v. Howard County Equity, No. 10-0776, 2011 WL 1584348 (Iowa Ct. App. Apr. 27, 2011), the Court of Appeals applied and extended K. Carr. There, the district court had dismissed a plaintiff’s case solely as a sanction for a rule 1.413 violation. The Court of Appeals reversed, explaining:

Dismissal solely under rule 1.413 may improperly restrict access to courts and raise due process concerns by depriving litigants of their “day in court.”
By contrast, rule 1.517(2)(b)(3) (governing discovery sanctions) explicitly authorizes dismissal in certain circumstances, suggesting that where the drafters intended dismissal to be available, they said so.
Iowa is free to interpret its own civil rules differently from federal courts, even when the rules share a common origin (here, Federal Rule of Civil Procedure 11).

Buhr thus framed dismissal under rule 1.413 as not permitted, absent some other independent basis.

4. Stare Decisis Cases: Book, Brewer-Strong, McElroy, Ramos

The court invokes several authorities to explain the high bar for overturning precedent:

Book v. Doublestar Dongfeng Tyre Co., 860 N.W.2d 576, 594 (Iowa 2015): “Stare decisis alone dictates continued adherence to our precedent absent a compelling reason to change the law.”
Brewer-Strong v. HNI Corp., 913 N.W.2d 235, 249 (Iowa 2018), quoting McElroy v. State, 703 N.W.2d 385, 394 (Iowa 2005): overturning precedent requires “the highest possible showing that a precedent should be overruled.”
Ramos v. Louisiana, 590 U.S. 83, 115 (2020) (Kavanaugh, J., concurring in part): defining the maxim of stare decisis—“to stand by the thing decided and not disturb the calm.”

These cases support the court’s reluctance to revisit K. Carr and Buhr, especially where a party raised the issue only at the further-review stage.

5. Dismissal as a “Rare Judicial Act”: Kendall/Hunt, Breitbach, Buhr

The court also situates its analysis within the broader Iowa tradition of viewing dismissal as an exceptional sanction:

Kendall/Hunt Publishing Co. v. Rowe, 424 N.W.2d 235, 240–41 (Iowa 1988): dismissal is a “rare judicial act,” quoting Edgar v. Slaughter, 548 F.2d 770, 773 (8th Cir. 1977).
Breitbach v. Christenson, 541 N.W.2d 840, 845 (Iowa 1995) (en banc): endorses the principle that litigants should be allowed to have disputes resolved on the merits whenever reasonably possible.
Buhr (supra): applies this reasoning in the rule 1.413 context, cautioning against dismissal as a sanction that threatens access to courts.

6. Inherent Authority: In re Guardianship of J.W.

The court references In re Guardianship of J.W., 991 N.W.2d 143 (Iowa 2023), where it held that dismissal based on ethical concerns stemming from a party-attorney’s conduct can fall within a court’s inherent authority in appropriate circumstances.

However, in Kraus, the district court did not invoke its inherent authority; it relied solely on rule 1.413. Thus, the Supreme Court declines to affirm the dismissal on a different ground that the district court itself did not articulate. This reinforces the requirement that trial courts must clearly identify the legal basis for any terminating sanction.

7. Scope of Further Review: County Bank v. Shalla, State v. Torres, State v. Warren, Richardson v. Commodore

The court cites County Bank v. Shalla, 20 N.W.3d 812, 818 (Iowa 2025), to emphasize that on further review, the Supreme Court may address only selected issues while leaving the Court of Appeals’ resolution of other issues intact.

It also cites several cases (State v. Torres, 989 N.W.2d 121 (Iowa 2023); State v. Warren, 955 N.W.2d 848 (Iowa 2021); Richardson v. Commodore, Inc., 599 N.W.2d 693 (Iowa 1999)) for the practice of declining to consider arguments raised for the first time in an application for further review, particularly arguments that would require overruling precedent.

C. The Court’s Legal Reasoning

1. Step One: Textual Analysis of Rule 1.413

The court begins with the language of rule 1.413(1). It notes:

The rule mandates “an appropriate sanction” for a violation.
The rule does not define “appropriate sanction” or expressly place limits on it.
The clause “which may include an order to pay . . . reasonable expenses . . . including a reasonable attorney fee” is grammatically a nonrestrictive clause. It provides an example of a possible sanction (monetary fees and costs), but does not limit the sanctions universe to this category.

From a purely textual standpoint, then, the term “appropriate sanction” is open-ended. The court acknowledges that nothing in the text itself expressly prevents dismissal from being one such sanction.

2. Step Two: Precedent Overrides the Broad Textual Reading

Despite the broad language of the rule, the court concludes it is bound by K. Carr’s interpretation that rule 1.413 “does not provide an independent basis for dismissal.”

The court emphasizes:

Continuity of interpretation: The relevant language of the rule has not changed in a way that would undermine K. Carr.
Reliance interests: For decades, Iowa litigants and courts have operated under the understanding that rule 1.413 permits sanctions but not dismissal as a standalone remedy.
Institutional stability: Overruling requires a “compelling reason”—a burden not met here, particularly given how the issue was raised (only in the application for further review).

In this way, the opinion illustrates a core feature of American appellate practice: even when text might allow a fresh reading, an existing interpretive precedent often controls unless and until the court deliberately decides to change course.

3. Step Three: Policy and Due Process Considerations

The court also grounds its adherence to K. Carr and Buhr in important policy considerations:

Dismissal should remain a “rare judicial act,” because it deprives parties of the opportunity to have claims decided on the merits.
Allowing dismissal solely as a sanction under rule 1.413 raises concerns about access to justice and due process, especially when a case could otherwise be resolved through more tailored means (e.g., monetary sanctions, evidentiary sanctions, or ruling on the merits through motions or trial).
Other rules (e.g., rule 1.517 on discovery sanctions) expressly provide for dismissal, supporting the inference that the civil rules system as a whole reserves dismissal for explicitly designated situations.

4. Step Four: Limiting the Role of Inherent Authority in This Case

Although Iowa courts possess inherent authority to sanction litigant and attorney misconduct, including dismissal in extreme cases, the Supreme Court refuses to retrofit that rationale here:

The district court explicitly and “solely” relied on rule 1.413 “independent of any other rule or power.”
The Supreme Court, reviewing for legal error, evaluates the ruling on the basis the district court actually used, not on hypothetical alternative grounds not invoked below.
Guardianship of J.W. shows that dismissal can be within inherent authority in appropriate circumstances, but such authority must be consciously invoked and justified in the record.

This keeps the doctrinal lines clean:

Rule-based sanctions (1.413, 1.517, etc.) operate within the confines of the specific rule and its interpretation.
Inherent authority exists but must be separately asserted and exercised judiciously.

5. Step Five: Result in This Case

Applying these principles, the court:

Accepts the lower courts’ conclusion that Matthew’s petition blatantly violated rule 1.413 (a conclusion not before the Supreme Court on further review);
Approves the attorney-fee award as a proper and supported sanction; and
Reverses the dismissal because:
- Rule 1.413, by itself, cannot justify dismissal; and
- No alternative basis (such as inherent authority or other rules) was cited and supported at the district court level.

The court closes by emphasizing that nothing in its decision prevents litigants from using other procedural rules to seek a pretrial determination on the merits (e.g., motions to dismiss, summary judgment). The limitation is specific: rule 1.413 is not a standalone dismissal rule.

D. Policy Considerations and Due Process

Beyond technical rule interpretation, the opinion reflects two deeper policy commitments.

1. Access to Courts and “Day in Court” Values

The idea that parties are entitled to have their disputes decided on the merits is central. While frivolous filings must be deterred, the sanctioning regime must balance:

The need to protect the judicial system and opposing parties from bad-faith or baseless litigation; and
The need to avoid prematurely or disproportionately ending potentially meritorious claims due to procedural missteps or attorney misconduct.

By cabining rule 1.413 to non-terminating sanctions (at least as an independent basis), the court protects this balance. It leaves open serious, case-ending repercussions for the most egregious conduct through other, more carefully structured avenues (e.g., rule 1.517, inherent authority, or substantive rulings on the merits).

2. Notice and Predictability in Sanctions Practice

A predictable sanctions regime enhances fairness:

If counsel and parties know that violating rule 1.413 may result in monetary sanctions, reputational consequences, or issue-related sanctions—but not outright dismissal—they can better calibrate their behavior and understand the risks.
Allowing dismissal under 1.413 without express textual support would blur the lines between sanctions for litigation misconduct and merit-based adjudication of claims.

Instead, the court’s reaffirmation of K. Carr and Buhr preserves a clear structural separation: rule 1.413 punishes improper filings, while other mechanisms address whether claims themselves warrant dismissal.

E. Relationship to Federal Rule 11 and Other Sanctioning Regimes

Iowa’s rule 1.413 is patterned on Federal Rule of Civil Procedure 11, but the court underscores that Iowa is not bound by federal interpretations. The Court of Appeals in Buhr already noted that Iowa’s approach diverges from some federal case law that permits dismissal as a Rule 11 sanction.

This opinion cements Iowa’s distinct path:

Federal cases sometimes treat dismissal as a permissible Rule 11 sanction in extreme situations.
Iowa, by contrast, reads rule 1.413 in light of its own precedents and policy preferences, limiting its role to non-terminating sanctions.

At the same time, Iowa does allow terminating sanctions under other rules:

Rule 1.517 (discovery sanctions) specifically allows dismissal of an action in response to serious discovery abuses.
Other rules and doctrines (e.g., rule 1.944 for want of prosecution, summary judgment rules, or dismissal for failure to state a claim) are also available to terminate litigation where warranted.

Thus, Iowa law draws a structural distinction between:

Misconduct in signing/filing pleadings (rule 1.413) → non-terminating sanctions such as attorney fees; and
Misconduct in litigation conduct more broadly (discovery violations, failure to prosecute, or egregious ethical misconduct) → potentially terminating sanctions under other rules or inherent authority.

F. Implications for Family Law and Civil Practice

1. For Family Law Practitioners

The factual context—a hasty post-decree modification petition filed without any real change in circumstances—highlights several practical points for family-law lawyers:

Modification standards remain substantive, not procedural. A party who regrets a stipulated decree cannot simply file an early modification petition to re-litigate what was just agreed to and adjudicated.
Rule 1.413 applies with full force in family law cases. Petitions for modification must be grounded in actual, material, and substantial changes of circumstances that occur after the decree.
Monetary sanctions for bad-faith modification filings are very real. Here, the sanction exceeds $7,000 in attorney fees plus interest, a significant deterrent.
However, dismissal as a punitive response to the filing itself is not authorized under rule 1.413 alone. Courts must still address whether the petition states a claim or survives other dispositive motions on their own terms.

In practice, a meritless modification petition like Matthew’s can still fail quickly, but by means of substantive or procedural adjudication (e.g., motion to dismiss for failure to state a claim, summary judgment, or denial on the merits after hearing) rather than dismissal as a stand-alone rule 1.413 sanction.

2. For Civil Litigators More Broadly

The decision has broader implications in all areas of civil practice:

Sanctions strategy. Lawyers seeking to combat frivolous or bad-faith pleadings should:
- Use rule 1.413 to obtain monetary and related sanctions; and
- Separately use dispositive motions (e.g., motions to dismiss, motions for summary judgment) or explicit dismissal-authorizing rules (e.g., rule 1.517) to terminate cases when appropriate.
Trial court orders must clearly identify their legal basis. When imposing severe sanctions—especially dismissal—district courts should specify whether they:
- Are acting under a particular rule (and which one);
- Are invoking their inherent authority; and
- Are basing dismissal on the merits of the claim (e.g., mootness, lack of legal claim) versus misconduct in litigation.
Appellate review will honor doctrinal boundaries. The Supreme Court will not retroactively recharacterize a rule-1.413 dismissal as an exercise of inherent authority unless the district court’s order supports that characterization.

3. For Judges

Judges confronted with egregious violations of rule 1.413 should:

Make detailed factual findings regarding the violation, including bad faith, lack of reasonable inquiry, and improper purpose;
Impose meaningful but proportionate sanctions (attorney fees, costs, possibly other nonterminating sanctions) under rule 1.413;
Consider whether other rules or inherent authority justify terminating sanctions, but make any such reliance explicit; and
Preserve parties’ ability to have claims resolved on the merits where possible, in line with the principle that dismissal is a “rare judicial act.”

V. Clarifying Complex Concepts

A. “Nonrestrictive Adjectival Clause”

The opinion briefly digresses into grammar to interpret rule 1.413’s wording. A “nonrestrictive clause” is a phrase that:

Provides extra information about a noun or phrase, but
Does not limit or define it.

In rule 1.413(1), the phrase:

“which may include an order to pay . . . the amount of the reasonable expenses . . . including a reasonable attorney fee”

is nonrestrictive. It tells us that attorney fees are one example of an “appropriate sanction,” but does not say that attorney fees are the only possible sanction.

B. “Independent Basis for Dismissal”

An “independent basis for dismissal” means a rule or doctrine that, standing alone, authorizes the court to terminate a case. For example:

Rule 1.517(2)(b)(3) (discovery sanctions) is an independent basis for dismissal in severe discovery abuse situations.
Rule 1.944 (want of prosecution) is an independent basis for dismissal when a party fails to move a case forward.

The court holds that rule 1.413 is not such a rule. It authorizes sanctions, but those sanctions must complement, not replace, the usual procedural mechanisms for ending cases.

C. “Stare Decisis”

“Stare decisis” is the doctrine that courts adhere to their own prior decisions to promote stability, predictability, and fairness. Overruling precedent requires a strong justification, especially when:

The legislature has not changed the underlying statute or rule;
The prior case has been relied on for many years; and
No compelling change in legal reasoning or circumstances has emerged.

The court applies stare decisis to maintain K. Carr and Buhr’s interpretation of rule 1.413, even though a purely textual re-analysis might allow a broader reading.

D. “Inherent Authority”

Courts possess “inherent authority” beyond what is specifically written in statutes or rules, allowing them to manage their own proceedings, enforce orders, and protect the integrity of the judicial process. This includes:

Sanctioning misconduct not covered by particular rules;
In extreme cases, dismissing actions as a remedy for grave abuses or ethical violations.

However, because this power is potent and not textually constrained, it must be:

Used sparingly;
Justified carefully in the record; and
Clearly distinguished from rule-based sanctions.

E. “Rare Judicial Act”

When the court calls dismissal a “rare judicial act,” it means:

Dismissal should generally be a last resort;
Courts should, when practical, use less severe sanctions or resolve disputes on the merits; and
Terminating sanctions are appropriate only in well-defined circumstances (e.g., persistent noncompliance, egregious misconduct, or clearly meritless claims as determined through proper procedural channels).

VI. Conclusion

In re the Marriage of Kraus offers a focused yet influential clarification of Iowa sanctions law. The Supreme Court:

Reaffirms that rule 1.413 is a powerful tool against frivolous or bad-faith filings, but
Holds that it does not provide an “independent basis for dismissal.”

The decision balances firm disapproval of abusive litigation tactics—evident in its acceptance of substantial attorney-fee sanctions—against a strong commitment to access to courts and the principle that dismissal is a “rare judicial act.”

For practitioners, the message is twofold:

Do not weaponize rule 1.413 as a shortcut to dismissal. Use it to obtain appropriate sanctions, and use other rules or merits-based motions to end cases.
Ensure any request for case-terminating relief clearly identifies and supports the proper legal basis (e.g., rule 1.517, inherent authority, or traditional dispositive motions).

For family-law litigants in particular, the case underscores that:

Post-decree modification petitions filed purely out of regret and without genuine changed circumstances can, and likely will, trigger rule 1.413 sanctions; but
Those sanctions will not, under rule 1.413 alone, extinguish the petition permanently. The petition’s fate must be decided through the ordinary merits-based procedures of Iowa civil practice.

By reaffirming K. Carr and Buhr, the Iowa Supreme Court provides clarity and stability in sanctions jurisprudence, ensuring that rule 1.413 remains a meaningful but carefully cabined mechanism for policing litigation misconduct, not a free-standing gateway to dismissal.