Justia Iowa Supreme Court Opinion Summaries

In this intrafamily dispute regarding farmland the Supreme Court affirmed the rulings of the district court denying substitute petitioners' petition for relief from elder abuse specifically seeking relief for the loss associated with certain real estate transactions, holding that the substitute petitioners failed to prove that their father was a vulnerable elder at the time of the challenged transactions.The substitute petitioners for their father filed this petition pursuant to Iowa Code 235F alleging that their brother and his son committed elder abuse against their father by unduly influencing the father to enter into below-mark-rate lease agreements to farm the father's land, to gift some of the land to the brother and his son, and to write a new will to reflect the gifted land. The district court concluded that the substitute petitioners failed to establish that their father was a "vulnerable elder" subject to "financial exploitation" within the meaning of chapter 235F. The Supreme Court affirmed, holding that the substitute petitioners filed to prove by a preponderance of the evidence that their father was vulnerable elder at the time of the challenged transactions. View "Struve v. Struve" on Justia Law

The Supreme Court vacated the decision of the court of appeals affirming the district court's denial of Defendant's motion for summary judgment, reversed the decision of the district court, and remanded to the district court for entry of summary judgment in favor of Defendants, holding that Plaintiffs' action was untimely.Plaintiffs, two beneficiaries of a trust, filed an action asking the district court to resolve a dispute with Defendant concerning the valuation date of the trust. Defendants moved for summary judgment on the grounds that Plaintiffs' action was untimely and the terms of the trust clearly provided the valuation date. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed the denial of summary judgment, holding that Plaintiffs failed timely to commence their action, and therefore, their claims were barred under Iowa Code 633A.4504. View "Konrardy v. Vincent Angerer Trust" on Justia Law

The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA).Here, the decedent, before his death, signed a beneficiary form listing the taxpayer as a contingent beneficiary of his brokerage account. That account transferred to the taxpayer upon the decedent's death. The Iowa Department of Revenue (IDOR) determined that the estate owed the inheritance tax on the full account value. The decedent’s grandchildren sued the taxpayer claiming that they were entitled to the brokerage account under the decedent’s will because the decedent lacked the mental capacity to execute an enforceable beneficiary designation for the account. The taxpayer settled the suit by transferring half the account value to the plaintiffs under an FSA. The taxpayer then sought a refund of part of the inheritance tax already paid. The IDOR denied a refund, determining that the taxpayer failed to establish incapacity. The district court affirmed. The court of appeals reversed, concluding that the FSA controlled the tax issue. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that, without an adjudication of incapacity, the FSA was not binding on the IDOR and could not avoid the inheritance tax. View "Nance v. Iowa Department of Revenue" on Justia Law

In this will contest, the district court did not abuse its discretion in denying the unsuccessful will contestant’s motion to amend the pleadings to conform to the proof at the close of his case.The contestant’s motion at issue sought to broaden the contestant’s undue influence claim to include all of the testator’s prior wills and codicils. The Supreme Court held that the last-minute amendment would have broadened the issues and the proof. In addition, this issue fell within precedent upholding denials of motions to amend under Iowa R. Civ. P. 1.457 when the motion is based on facts the movant knew or should have known before trial. As to the contestant’s other issue asking the Supreme Court to overturn a ruling on burden of proof that was incorporated within a pretrial order denying summary judgment, this issue was not preserved for review. Accordingly, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "In re Estate of Margaret E. Workman" on Justia Law

David Steinberg and Steven Steinberg, brothers and the sole beneficiaries of the Steinberg Family Living Trust, requested a declaration of how a Minnesota farm and an Iowa farm should be distributed. The Minnesota farm, which was part of the trust, was acquired after the creation of the trust through a like-kind tax exchange of property. The exchanged property was specifically bequeathed to Steven but the acquired farm was not specifically bequeathed to either beneficiary. The district court ordered the Minnesota farm to be distributed equally between the brothers, concluding that the specific bequest was adeemed because the bequeathed parcel of land was no longer an asset of the trust and there was no exception to the doctrine of ademption for the like-kind tax exchange of property. The court also struck a provision of the trust granting Steven the option to purchase the Iowa farm from David. The Supreme Court (1) affirmed the district court’s decision to the extent the court declared the specific bequest to Steven was adeemed and concluded that the Minnesota farm was to be distributed equally between the brothers; and (2) reversed the decision to the extent it granted summary judgment to David on the disputed trust provision due to genuine issues of material fact. View "Steinberg v. Steinberg" on Justia Law

Joseph Gantner died in 2015, survived by his wife, Rachel Gantner, and two daughters, Meredith and Paige Gantner. After Joseph’s will was admitted to probate, Rachel filed for an elective share of Joseph’s estate and also requested a spousal support allowance. Meredith and Paige resisted Rachel’s application for spousal support, maintaining that several individual retirement accounts (IRAs) did not constitute part of the probate estate and, therefore, were beyond the reach of Rachel’s spousal allowance. As relevant to this appeal, Rachel was not a beneficiary of those IRAs. Rather, the executor confirmed that Meredith and Paige were their cobeneficaries. The probate court denied Rachel’s application for spousal allowance, concluding that the IRAs could not be used to pay an allowance to Rachel, who was not a beneficiary of those IRAs. Rachel appealed, arguing that she may reach the IRAs because they were “a transfer at death of a security registered in beneficiary form” under Iowa Code 633D.8. The Supreme Court affirmed, holding that chapter 633D does not apply to an IRA where one or more nonspouses are designated the beneficiaries. View "In re Estate of Joseph C. Gantner III" on Justia Law

Testator executed a last will and testament devising property to her adult son and daughter. After the will was executed but before Testator’s death, Son was adopted by his paternal aunt. After Testator’s death, Daughter filed this action seeking a declaratory judgment establishing that the adoption terminated Son’s ability to inherit under Mother’s will, which identified him as a beneficiary both by name and by membership in a class. The district court concluded that Son’s adoption out of his biological family did not preclude him from taking under Mother’s will. The Supreme Court affirmed, holding that the testamentary gift to Son as a named beneficiary and as a member of a class did not fail because of his adoption as an adult after Testator executed her will. View "Roll v. Newhall" on Justia Law

The administrators of Decedent’s estate listed residential real estate for sale. Decedent’s common law spouse objected to the proposed sale, claiming it was her marital home. The district court recognized the surviving spouses’s common law rights but nonetheless approved the sale. The buyers took possession and made improvements to the home. Thereafter, the court of appeals reversed and remanded for consideration of the homestead interest of the spouse. On remand, the district court gave the surviving spouse the option of taking possession of the home upon paying the buyers a substantial part of the cost of their improvements to the home or receiving the proceeds from the estate’s sale of the real estate. The Supreme Court affirmed as modified, holding (1) the surviving spouse could retake possession upon payment of the approximate value of the home before the improvements were made less any credit to which she was entitled from the buyers for rent during the period the spouse had been dispossessed; and (2) the spouse could transfer title to the buyers and receive the proceeds from the estate’s sale of the home plus credit for rent from the date of the conveyance to the buyers until the date of judgment. View "In re Estate of Waterman" on Justia Law

In 1991, Husband and Wife were married in Florida. Later that year, the couple signed a postnuptial agreement expressly providing that Florida law would apply. The agreement contained a provision stating that Wife waived all claims against Husband’s estate upon his death, including her elective share. In 2005, the couple moved to Iowa. After Husband died in 2012, Wife claimed her spousal elective share under Iowa law. The agreement was enforceable under Florida law, but Wife argued that the agreement could not be enforced in Iowa because it would violate Iowa’s public policy against postnuptial agreements waiving a spouse’s elective share. The district court denied relief based on the choice of law provision in the agreement. The Supreme Court affirmed, holding that Florida law applied to the enforceability of Wife’s waiver of her spousal elective share contained in the agreement. View "Hussemann v. Hussemann " on Justia Law

Elmer Gaede, who owned a 120-acre farm together with his wife, died testate on February 2005. Elmer’s daughter, Diean, was named executor under the will. Diean designated Ivan Ackerman to render legal services in the administration of the estate. During the pendency of the probate proceedings, Elmer’s son James and his wife, who were leasing the farm, exercised the option under the lease agreement to purchase the farm. Diean later filed this legal malpractice lawsuit against Ackerman, alleging that Ackerman failed to adequately protect her personal interests relating to the enforceability of the option. The district court granted summary judgment for Ackerman, determining that Ackerman did not have a duty to protect Diean’s personal interests. The court of appeals reversed, holding that a factual dispute existed over the question of whether Diean had a reasonable expectation that Ackerman was representing her personal interests. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that insufficient facts supported Diean’s claim that Ackerman reasonably understood that Diean expected him to protect her personal interests in challenging the option. View "Sabin v. Ackerman" on Justia Law