implied waiver (Iowa) · Go Syfert
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implied waiver in Iowa

21 Iowa opinions name it 2 courts 1942–2026 5 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Dodd v. Fleetguard, Inc.green
iowactapp · 2008 · cited in 2 Iowa opinions naming this issue, 2011–2021
2 sentences

2021IBP, Inc. v. Harker, 633 N.W.2d 322, 327 (Iowa 2001); cf. Dodd v. Fleetguard, Inc., 759 N.W.2d 133, 140 (Iowa Ct. App. 2008) (relying on Harker, 633 N.W.2d at 327 , and concluding “section 85.39 does not include an implied requirement that the claimant ultimately prove the injury arose out of and in the course of employment” in order to satisfy the requirements under section 85.39 for reimbursement for IME).

2011In Dodd , we noted the purpose behind section 85.39 can be explained by the unequal financial position of the parties and ruled: “Section 85.39 does not include an implied requirement that the claimant ultimately prove the injury arose out of and in the course of employment.” Id.

12
Travelers Indemnity Co. v. Fieldsgreen
iowa · 1982 · cited in 1 Iowa opinions naming this issue, 2026–2026
1 sentence

2026See id.

11
IBP, Inc. v. Harkergreen
iowa · 2001 · cited in 1 Iowa opinions naming this issue, 2021–2021
2 sentences

2021IBP, Inc. v. Harker, 633 N.W.2d 322, 327 (Iowa 2001); cf. Dodd v. Fleetguard, Inc., 759 N.W.2d 133, 140 (Iowa Ct. App. 2008) (relying on Harker, 633 N.W.2d at 327 , and concluding “section 85.39 does not include an implied requirement that the claimant ultimately prove the injury arose out of and in the course of employment” in order to satisfy the requirements under section 85.39 for reimbursement for IME).

2021IBP, Inc. v. Harker, 633 N.W.2d 322, 327 (Iowa 2001); cf. Dodd v. Fleetguard, Inc., 759 N.W.2d 133, 140 (Iowa Ct. App. 2008) (relying on Harker, 633 N.W.2d at 327 , and concluding “section 85.39 does not include an implied requirement that the claimant ultimately prove the injury arose out of and in the course of employment” in order to satisfy the requirements under section 85.39 for reimbursement for IME).

11
Union County v. Piper Jaffray & Co.green
iasd · 2008 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017Wash. 1975), persuasive in addressing implied waiver of the attorney-client privilege.5 Hearn provides there are three criteria to find an implied waiver of the attorney- client privilege: (1) assertion of the privilege was a result of some affirmative act, such as filing suit [or raising an 4 The additional information included questions pertaining to twice deducting the $5000 deductible, not paying interest on the $83,000, and who authorized Acuity’s counsel to write the July 29, 2014 letter. 5 See, e.g., Union Cty., Iowa v. Piper Jaffray & Co, Inc., 248 F.R.D. 217, 222 (S.D.

11
State v. Connergreen
iowa · 1980 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015State v. Conner, 292 N.W.2d 682, 684 (1980); State v. Kernes, 262 N.W.2d 602, 605 (Iowa 1978) (defining recklessness as “conduct evidencing either a willful or wanton disregard for the safety of others”).

11
State v. Kernesgreen
iowa · 1978 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015State v. Conner, 292 N.W.2d 682, 684 (1980); State v. Kernes, 262 N.W.2d 602, 605 (Iowa 1978) (defining recklessness as “conduct evidencing either a willful or wanton disregard for the safety of others”).

11
Snell v. Superior Courtgreen
calctapp · 1984 · cited in 1 Iowa opinions naming this issue, 2009–2009
2 sentences

2009P’ship v. Sanguonchitte, 920 So.2d 711, 712 (Fla.Dist.Ct.App.2006); accord Palm Beach Gardens Cmty. Hosp., Inc. v. O’Brien, 651 So.2d 783, 784 (Fla.Dist.Ct.App.1995); see also Brownwood Reg’l Hosp. v. Eleventh Ct. of Appeals, 927 S.W.2d 24, 27 (Tex.1996) (holding that a hospital’s peer review records are not discoverable despite the plaintiffs’ claim that this “severely compromises their ability to present evidence in support of their negligent credentialing claim”); Snell v. Superior Court, 158 Cal. App.3d 44 , 204 Cal.Rptr. 200, 202 (1984) (holding that the “relevance of a hospital’s records

2009P’ship v. Sanguonchitte, 920 So.2d 711, 712 (Fla.Dist.Ct.App.2006); accord Palm Beach Gardens Cmty. Hosp., Inc. v. O’Brien, 651 So.2d 783, 784 (Fla.Dist.Ct.App.1995); see also Brownwood Reg’l Hosp. v. Eleventh Ct. of Appeals, 927 S.W.2d 24, 27 (Tex.1996) (holding that a hospital’s peer review records are not discoverable despite the plaintiffs’ claim that this “severely compromises their ability to present evidence in support of their negligent credentialing claim”); Snell v. Superior Court, 158 Cal. App.3d 44 , 204 Cal.Rptr. 200, 202 (1984) (holding that the “relevance of a hospital’s records

11
COLUMBIA/JFK MEDICAL CTR. v. Sanguonchittegreen
fladistctapp · 2006 · cited in 1 Iowa opinions naming this issue, 2009–2009
1 sentence

2009P’ship v. Sanguonchitte, 920 So.2d 711, 712 (Fla.Dist.Ct.App.2006); accord Palm Beach Gardens Cmty. Hosp., Inc. v. O’Brien, 651 So.2d 783, 784 (Fla.Dist.Ct.App.1995); see also Brownwood Reg’l Hosp. v. Eleventh Ct. of Appeals, 927 S.W.2d 24, 27 (Tex.1996) (holding that a hospital’s peer review records are not discoverable despite the plaintiffs’ claim that this “severely compromises their ability to present evidence in support of their negligent credentialing claim”); Snell v. Superior Court, 158 Cal. App.3d 44 , 204 Cal.Rptr. 200, 202 (1984) (holding that the “relevance of a hospital’s records

11
Brownwood Regional Hospital v. Eleventh Court of Appealsgreen
tex · 1996 · cited in 1 Iowa opinions naming this issue, 2009–2009
1 sentence

2009P’ship v. Sanguonchitte, 920 So.2d 711, 712 (Fla.Dist.Ct.App.2006); accord Palm Beach Gardens Cmty. Hosp., Inc. v. O’Brien, 651 So.2d 783, 784 (Fla.Dist.Ct.App.1995); see also Brownwood Reg’l Hosp. v. Eleventh Ct. of Appeals, 927 S.W.2d 24, 27 (Tex.1996) (holding that a hospital’s peer review records are not discoverable despite the plaintiffs’ claim that this “severely compromises their ability to present evidence in support of their negligent credentialing claim”); Snell v. Superior Court, 158 Cal. App.3d 44 , 204 Cal.Rptr. 200, 202 (1984) (holding that the “relevance of a hospital’s records

11
Palm Beach Gardens Community Hospital, Inc. v. O'BRIENgreen
fladistctapp · 1995 · cited in 1 Iowa opinions naming this issue, 2009–2009
1 sentence

2009P’ship v. Sanguonchitte, 920 So.2d 711, 712 (Fla.Dist.Ct.App.2006); accord Palm Beach Gardens Cmty. Hosp., Inc. v. O’Brien, 651 So.2d 783, 784 (Fla.Dist.Ct.App.1995); see also Brownwood Reg’l Hosp. v. Eleventh Ct. of Appeals, 927 S.W.2d 24, 27 (Tex.1996) (holding that a hospital’s peer review records are not discoverable despite the plaintiffs’ claim that this “severely compromises their ability to present evidence in support of their negligent credentialing claim”); Snell v. Superior Court, 158 Cal. App.3d 44 , 204 Cal.Rptr. 200, 202 (1984) (holding that the “relevance of a hospital’s records

11
Charles Gabus Ford, Inc. v. Iowa State Highway Commissiongreen
iowa · 1974 · cited in 1 Iowa opinions naming this issue, 1989–1989
1 sentence

1989In Charles Gabus Ford v. Iowa State Highway Commission, 224 N.W.2d 639, 646-47 (Iowa 1974), we refused to extend the rationale of Kersten to find such an implied waiver of immunity in a tort action for damages.

11
People Ex Rel. Schribner v. Caldwellgreen
colo · 1938 · cited in 1 Iowa opinions naming this issue, 1948–1948
1 sentence

1948See cases cited in the annotations to the case of Barlow v. Hoffman, 103 Colo. 286 , 86 P. 2d 239 , 120 A. L.

11
Barlow v. Hoffmangreen
colo · 1938 · cited in 1 Iowa opinions naming this issue, 1948–1948
1 sentence

1948See cases cited in the annotations to the case of Barlow v. Hoffman, 103 Colo. 286 , 86 P. 2d 239 , 120 A. L.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Fisher v. Dallas County green
iowa · 1985
2 sentences

2017Question 1: As a matter of Iowa law, does the doctrine of implied immunity of drainage districts as applied in cases such as Fisher v. Dallas County, 369 N.W.2d 426 (Iowa 1985), grant drainage districts unqualified immunity from all of the damage claims set forth in the complaint (docket no. 2)?

2017Question 1: As a matter of Iowa law, does the doctrine of implied immunity of drainage districts as applied in cases such as Fisher v. Dallas County, 369 N.W.2d 426 (Iowa 1985), grant drainage districts unqualified immunity from all of the damage claims set forth in the Complaint (docket no. 2)?

32017–2017
Tina Lee v. State of Iowa, Polk County Clerk of Court green
iowa · 2012
2 sentences

2024The implied waiver found in Kersten Co. and Dvorak “reflected our belief that the State is answerable for the legal relationships it voluntarily creates.” Lee, 815 N.W.2d at 740 .

2024The implied waiver found in Kersten Co. and Dvorak “reflected our belief that the State is answerable for the legal relationships it voluntarily creates.” Lee, 815 N.W.2d at 740 .

22024–2024
Gorman v. City Development Board green
iowa · 1997
2 sentences

2016Id.

2016Id.

22016–2016
Koss v. Palmer Water Department green
mad · 2013
1 sentence

2021The parties also cite us to Koss v. Palmer Water Department, 977 F. Supp. 2d 28 , 29–30 (D.

12021–2021
Berghuis v. Thompkins green
scotus · 2010
2 sentences

2015Specifically, if “the prosecution shows that a Miranda warning was given and that it was understood by the accused, an accused’s uncoerced statement establishes an implied waiver of the right to remain silent.” Id.

2015Generally, “the law can presume that an individual who, with a full understanding of his or her rights, acts in a manner inconsistent with their exercise has made a deliberate choice to relinquish the protection those rights afford.” Id. at 385 .

12015–2015
Ewing v. Allied Construction Services green
iowa · 1999
1 sentence

2008In light of this stated purpose, the plain text of the statute, and the fact that we “liberally construe workers’ compensation statutes in favor of the worker,” Ewing, 592 N.W.2d at 691 , we conclude section 85.39 does not include an implied requirement that the claimant ultimately prove the injury arose out of and in the course of employment.

12008–2008
Bishop v. Keystone Area Education Agency Number 1 green
iowa · 1979
1 sentence

1993Bishop, 275 N.W.2d at 753 .

11993–1993
Lisbon Bank and Trust Company v. Murray green
iowa · 1973
1 sentence

1987Lisbon Bank and Trust, 206 N.W.2d at 99 .

11987–1987
North American Ginseng Co. v. Gilbertson neutral
iowa · 1925
2 sentences

1942In North American Ginseng Co. v. Gilbertson, 200 Iowa 1349, 1353 , 206 N. W. 610, 612 , we said: “An implied waiver is, in a sense, more or less a direct kin to an estoppel.

1942In North American Ginseng Co. v. Gilbertson, 200 Iowa 1349, 1353 , 206 N. W. 610, 612 , we said: “An implied waiver is, in a sense, more or less a direct kin to an estoppel.

11942–1942
Hexom v. Knights of Maccabees of the World green
iowa · 1908
2 sentences

1942There is, however, a distinction often to be made between them, and a waiver does not necessarily include all of the elements of an estoppel.” In Hexom v. Knights of Maccabees, 140 Iowa 41, 46 , 117 N. W. 19, 20 , the court said: “A waiver is the intentional relinquishment of a known right, or such conduct as warrants an inference of such relinquishment, * * * and, where conduct is relied upon to constitute waiver, it must appear that the insured was induced by the association to do or omit some act which he would not otherwise have done or omitted. 3 Am. & Eng.

1942There is, however, a distinction often to be made between them, and a waiver does not necessarily include all of the elements of an estoppel.” In Hexom v. Knights of Maccabees, 140 Iowa 41, 46 , 117 N. W. 19, 20 , the court said: “A waiver is the intentional relinquishment of a known right, or such conduct as warrants an inference of such relinquishment, * * * and, where conduct is relied upon to constitute waiver, it must appear that the insured was induced by the association to do or omit some act which he would not otherwise have done or omitted. 3 Am. & Eng.

11942–1942

Statutes the citing opinions construe

IA § Iowa Code § 17A.19 (6) IA § Iowa Code § 455A.15 (3) IA § Iowa Code § 455A.16 (3) IA § Iowa Code § 455A.6 (3) IA § Iowa Code § 455B.173 (3) IA § Iowa Code § 468.1 (3) IA § Iowa Code § 468.37 (3) IA § Iowa Code § 468.54 (3) IA § Iowa Code § 468.74 (3) IA § Iowa Code § 626.24 (3) IA § Iowa Code § 657.3 (3) IA § Iowa Code § 679A.19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 323 (1857–2026) TX 164 (1877–2026) IL 101 (1888–2026) IN 89 (1882–2026) CO 80 (1981–2026) WA 79 (1929–2025) CT 74 (1928–2022) FL 74 (1907–2025) PA 61 (1896–2025) LA 61 (1916–2020) NY 59 (1841–2025) OH 58 (1890–2026) TN 52 (1896–2022) MO 42 (1885–2024) MD 41 (1941–2024) MI 41 (1923–2026) GA 40 (1898–2025) AZ 35 (1920–2023) NJ 32 (1862–2026) NC 30 (1822–2025) AL 30 (1849–2024) AK 28 (1973–2022) KS 26 (1884–2024) VA 23 (1925–2024) IA 21 (1942–2026) OR 19 (1887–2026) MA 19 (1905–2023) MN 19 (1902–2016) NV 19 (1978–2022) AR 16 (1892–2014) OK 16 (1913–2023) VT 15 (1940–2024) NM 15 (1953–2020) SD 15 (1957–2026) KY 15 (1931–2020) ID 14 (1961–2020) SC 14 (1932–2020) MT 13 (1929–2025) ME 13 (1915–2023) NH 12 (1983–2015) NE 12 (1940–2018) DE 11 (1957–2025) RI 11 (1896–2024) UT 10 (1935–2025) MS 10 (1923–2022) WY 10 (1933–2025) DC 8 (1967–2006) ND 8 (1910–2006) WI 7 (1987–2023) HI 5 (1977–2018) WV 4 (1937–2026) VI 3 (2008–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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