bond requirement (Iowa) · Go Syfert
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bond requirement in Iowa

14 Iowa opinions name it 2 courts 1885–2025 7 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 (7)

CaseFollowedCited
In the Interest of M.W. and Z.W., Minor Children, R.W., Mothergreen
iowa · 2016 · cited in 5 Iowa opinions naming this issue, 2024–2025
2 sentences

2025See In re M.W., 876 N.W.2d 212, 225 (Iowa 2016) (declining to apply the bond exception under section 232.116(3)(c) despite “some bond between” the parent and children, as the children had been out of the parent’s care for nearly two years and had “achieved stability” in another placement).

2025See In re M.W., 876 N.W.2d 212, 225 (Iowa 2016) (declining to apply the bond exception under section 232.116(3)(c) despite “some bond between” the parent and children, as the children had been out of the parent’s care for nearly two years and had “achieved stability” in another placement).

55
Star Equipment, Ltd. v. State of Iowa, Iowa Department of Transportationgreen
iowa · 2014 · cited in 2 Iowa opinions naming this issue, 2024–2024
2 sentences

2024See 6 generally Star Equip., Ltd., 843 N.W.2d at 452–53 (addressing the bond requirement).

2024Co. v. City of Marion, 577 N.W.2d 657 , 659– 62 (Iowa 1998) (recognizing the interplay between sections of chapter 573 based upon the party’s status and the claims made and resolving those conflicts in the language of various sections); see also Star Equip., 843 N.W.2d at 454 (analyzing the reality of an exception to the bond requirement for “targeted small businesses” so as to allow subcontractors a remedy against the public entity for unpaid claims); Accurate Controls, Inc. v. Cerro Gordo Cnty.

22
Accurate Controls, Inc. v. Cerro Gordo County Board of Supervisorsgreen
iand · 2009 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024Bd. of Supervisors, 627 F. Supp. 2d 976, 1007 (N.D.

11
State v. DeCampgreen
iowa · 2001 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014See State v. DeCamp, 622 N.W.2d 290, 294 (Iowa 2001) (“[0]ur first task is to look to the language of the statute to determine the legislative intent.”)- The second paragraph of Iowa Code section 573.2 refers to the TSB bond waiver and states: If the requirement for a bond is waived pursuant to section 12.44, a person, firm, or corporation, having a contract with the targeted small business or with subcontractors of the targeted small business, for labor performed or materials furnished, in the performance of the contract on account of which the bond was waived, is entitled to any remedy provi

2014Id. (emphasis added). “ ‘[W]e give weight to explanations attached to bills as indications of legislative intent.’ ” Root v. Toney, 841 N.W.2d 83, 88 (Iowa 2013) (quoting City of Cedar Rapids v. James Props., Inc., 701 N.W.2d 673, 677 (Iowa 2005)). 3 We have not had occasion to interpret section 573.2 as amended in 1988.

11
Graham v. Worthingtongreen
iowa · 1966 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014In Graham v. Worthington, 259 Iowa 845, 865 , 146 N.W.2d 626, 639 (1966), the appellant raised an article VII, section 1 challenge to the state’s assumption of respondeat superior liability for the torts of state employees, arguing when “an employee of the state commits a tort, the employee is primarily liable, the state’s obligation secondary, and as a 13An ancillary benefit to the state is that the bond waiver promotes TSBs by enabling them to bid on public projects. 14We also recognize that the state has the ability to limit its exposure to subcontractors’ claims because it is the owner of

2014In Graham v. Worthington, 259 Iowa 845, 865 , 146 N.W.2d 626, 639 (1966), the appellant raised an article VII, section 1 challenge to the state’s assumption of respondeat superior liability for the torts of state employees, arguing when “an employee of the state commits a tort, the employee is primarily liable, the state’s obligation secondary, and as a 13An ancillary benefit to the state is that the bond waiver promotes TSBs by enabling them to bid on public projects. 14We also recognize that the state has the ability to limit its exposure to subcontractors’ claims because it is the owner of

11
Teri Root v. Talton Toneygreen
iowa · 2013 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Id. (emphasis added). “ ‘[W]e give weight to explanations attached to bills as indications of legislative intent.’ ” Root v. Toney, 841 N.W.2d 83, 88 (Iowa 2013) (quoting City of Cedar Rapids v. James Props., Inc., 701 N.W.2d 673, 677 (Iowa 2005)).3 We have not had occasion to interpret section 573.2 as amended in 1988.

2014Id. (emphasis added). “ ‘[W]e give weight to explanations attached to bills as indications of legislative intent.’ ” Root v. Toney, 841 N.W.2d 83, 88 (Iowa 2013) (quoting City of Cedar Rapids v. James Props., Inc., 701 N.W.2d 673, 677 (Iowa 2005)). 3 We have not had occasion to interpret section 573.2 as amended in 1988.

11
City of Cedar Rapids v. James Properties, Inc.green
iowa · 2005 · cited in 1 Iowa opinions naming this issue, 2014–2014
2 sentences

2014Id. (emphasis added). “ ‘[W]e give weight to explanations attached to bills as indications of legislative intent.’ ” Root v. Toney, 841 N.W.2d 83, 88 (Iowa 2013) (quoting City of Cedar Rapids v. James Props., Inc., 701 N.W.2d 673, 677 (Iowa 2005)).3 We have not had occasion to interpret section 573.2 as amended in 1988.

2014Id. (emphasis added). “ ‘[W]e give weight to explanations attached to bills as indications of legislative intent.’ ” Root v. Toney, 841 N.W.2d 83, 88 (Iowa 2013) (quoting City of Cedar Rapids v. James Props., Inc., 701 N.W.2d 673, 677 (Iowa 2005)). 3 We have not had occasion to interpret section 573.2 as amended in 1988.

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 (7)

CaseCitedYears
Employers Mutual Casualty Co. v. City of Marion green
iowa · 1998
1 sentence

2024Co. v. City of Marion, 577 N.W.2d 657 , 659– 62 (Iowa 1998) (recognizing the interplay between sections of chapter 573 based upon the party’s status and the claims made and resolving those conflicts in the language of various sections); see also Star Equip., 843 N.W.2d at 454 (analyzing the reality of an exception to the bond requirement for “targeted small businesses” so as to allow subcontractors a remedy against the public entity for unpaid claims); Accurate Controls, Inc. v. Cerro Gordo Cnty.

12024–2024
Comfort v. Kittle green
iowa · 1890
2 sentences

2011We declined to allow the term “recognizance” to include a bond requirement, noting that the power to require a bond of a witness is “unusual and extraordinary” and should not be exercised “where authority is doubtful.” Id. at 183-84 , 46 N.W. at 990 .

2011We declined to allow the term “recognizance” to include a bond requirement, noting that the power to require a bond of a witness is “unusual and extraordinary” and should not be exercised “where authority is doubtful.” Id. at 183-84 , 46 N.W. at 990 .

12011–2011
De Koning v. Mellema green
iowa · 1995
1 sentence

2007Id. at 396 .

12007–2007
Fuentes v. Shevin green
scotus · 1972
2 sentences

1977The Court concluded, “the minimal deterrent effect of a bond requirement is, in a practical sense, no substitute for an informed evaluation by a neutral official.” Fuentes, supra, 407 U.S. at 83 , 92 S.Ct. at 1995-1996 , 32 L.Ed.2d at 572 .

1977The Court concluded, “the minimal deterrent effect of a bond requirement is, in a practical sense, no substitute for an informed evaluation by a neutral official.” Fuentes, supra, 407 U.S. at 83 , 92 S.Ct. at 1995-1996 , 32 L.Ed.2d at 572 .

11977–1977
Field v. Schricher neutral
· 1862
1 sentence

1926But we have said: “When, from the language used, a legitimate statutory object and purpose can be seen to have been intended, it will not be presumed that the parties voluntarily made a bond only good at common law.” Field v. Schricher, 14 Iowa 119 .

11926–1926
Murray v. Thiessen neutral
iowa · 1901
1 sentence

1903In Murray v. Thiessen, 114 Iowa, 657 , we held that under allegation of notice plaintiff could not introduce evidence of the execution of a bond, but in the case now before us plaintiff pleaded the execution of a bond.

11903–1903
Jordan v. Kavanaugh neutral
· 1884
1 sentence

1885It is said that the plaintiff could have maintained an action on the bond under the rule established in Jordan v. Kavanagh, 63 Iowa, 152 , and Baker v. Bryan, 64 Id., 561.

11885–1885

Statutes the citing opinions construe

IA § Iowa Code § 232.116 (5) IA § Iowa Code § 573.12 (3) IA § Iowa Code § 573.13 (3) IA § Iowa Code § 573.14 (3) IA § Iowa Code § 573.16 (3) IA § Iowa Code § 573.18 (3) IA § Iowa Code § 573.2 (3) IA § Iowa Code § 573.21 (3) IA § Iowa Code § 573.3 (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

PA 136 (1922–2026) FL 77 (1971–2026) TX 69 (1882–2026) IL 55 (1904–2025) CA 51 (1930–2025) OH 41 (1961–2026) GA 32 (1881–2024) NY 22 (1861–2025) MA 21 (1970–2025) SC 16 (1932–2024) VA 15 (1940–2024) WA 14 (1934–2025) IA 14 (1885–2025) AZ 14 (1984–2020) AL 13 (1843–2015) NJ 13 (1964–2005) CT 13 (1972–2018) MO 12 (1978–2021) LA 11 (1842–2019) KY 10 (1878–2026) MI 10 (1975–2025) TN 10 (1964–2025) CO 9 (1947–2015) NC 9 (1893–2010) MD 9 (1925–2004) IN 8 (1934–2024) MS 8 (2007–2021) WV 6 (1923–2023) DC 6 (1981–2002) DE 5 (1983–2023) WY 5 (1931–2025) MN 5 (1959–2005) SD 5 (1926–2014) KS 4 (1936–2022) NH 4 (1964–2019) ID 4 (1983–2008) AR 4 (1908–2023) UT 4 (1979–2022) HI 4 (2020–2026) AK 4 (1986–1997) NV 4 (2011–2018) ME 4 (1935–2022) RI 3 (2003–2008) OR 3 (1946–2016) OK 3 (1920–1980) WI 3 (1981–2019) NM 2 (2012–2019) NE 2 (2022–2025) VI 2 (2013–2017)

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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