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12 Iowa opinions name it 2 courts 1981–2025 1 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.
| Case | Followed | Cited |
|---|---|---|
Knauss v. City of Des Moinesgreen2 sentences1994Under the pro tanto credit rule, we "allow a dollar-for-dollar credit against a plaintiff's personal injury verdict for sums received in settlement from other tortfeasors." Knauss v. City of Des Moines, 357 N.W.2d 573, 578 (Iowa 1984). 1994Under the pro tanto credit rule, we “allow a dollar-for-dollar credit against a plaintiffs personal injury verdict for sums received in settlement from other tortfeasors.” Knauss v. City of Des Moines, 357 N.W.2d 573, 578 (Iowa 1984). | 3 | 3 |
Greiner v. Hicksgreen2 sentences1995The policy reflected in the pro tanto credit rule is “that the plaintiff should receive no more than has been lost as the result of some tortious act.” Thomas v. Solberg, 442 N.W.2d 73, 74 (Iowa 1989); accord Greiner, 231 Iowa at 146-47 , 300 N.W. at 731 . 1995The policy reflected in the pro tanto credit rule is “that the plaintiff should receive no more than has been lost as the result of some tortious act.” Thomas v. Solberg, 442 N.W.2d 73, 74 (Iowa 1989); accord Greiner, 231 Iowa at 146-47 , 300 N.W. at 731 . | 2 | 4 |
Jamieson v. Harrisongreen2 sentences2004It follows, then, that the pro tanto credit rule would apply and any payment made by Everen Securities or Paxton would serve to reduce their joint liability to Clauss to the extent of the payment made. 1 See Jamieson, 532 N.W.2d at 782 (pro tanto credit rule continues to govern where proportionate credit rule of comparative fault statute does not apply). 2004This type of credit, known as the pro tanto credit rule, “is designed to prevent a double recovery by the injured party.” Jamieson v. Harrison, 532 N.W.2d 779, 781-82 (Iowa 1995). | 2 | 2 |
Thomas v. Solberggreen2 sentences2025And under Thomas, our supreme court opined that “Iowa Code chapter 668 was intended to eliminate the pro tanto credit rule for tort actions tried after July 1, 1984.” Thomas, 442 N.W.2d at 77 . 1995The policy reflected in the pro tanto credit rule is “that the plaintiff should receive no more than has been lost as the result of some tortious act.” Thomas v. Solberg, 442 N.W.2d 73, 74 (Iowa 1989); accord Greiner, 231 Iowa at 146-47 , 300 N.W. at 731 . | 1 | 3 |
Glidden v. Germangreen2 sentences1995Glidden v. German, 360 N.W.2d 716, 718 (Iowa 1984). 1987We conclude the Iowa legislature intended that statute to eliminate the pro tanto credit rule of Glidden v. German, 360 N.W.2d 716 (Iowa 1984), with the change applicable *340 to all tort actions tried after July 1, 1984. | 1 | 3 |
Tratchel v. Essex Group, Inc.green2 sentences1995Tratchel v. Essex Group, Inc., 452 N.W.2d 171, 181 (Iowa 1990). 1995Tratchel v. Essex Group, Inc., 452 N.W.2d 171, 181 (Iowa 1990). | 1 | 1 |
Citizens First National Bank v. Hoytgreen2 sentences1995Citizens First Nat’l Bank, 297 N.W.2d at 332. 1995Citizens First Nat'l Bank, 297 N.W.2d at 332 . | 1 | 1 |
Freeman v. Ernst & Younggreen2 sentences1994See Freeman v. Ernst & Young, 516 N.W.2d 835, 838-39 (Iowa 1994). 1994See Freeman v. Ernst & Young, 516 N.W.2d 835, 838-39 (Iowa 1994). | 1 | 1 |
Kopsas Ex Rel. Kopsas v. Iowa Great Lakes Sanitary Districtgreen1 sentence1989See, e.g., Kopsas v. Iowa Great Lakes Sanitary Dist., 407 N.W.2d 339, 339-40 (Iowa 1987); Glidden, 360 N.W.2d at 720 . | 1 | 1 |
Wadle v. Jonesgreen2 sentences1989See Greiner, 231 Iowa at 146-47 , 300 N.W. at 730-31 ; accord Wadle, 312 N.W.2d at 512 . 1989Id.; accord Wadle v. Jones, 312 N.W.2d 510, 512 (Iowa 1981). | 1 | 1 |
Bradley v. Appalachian Power Co.green2 sentences1984See, e.g., Continental Insurance Co. v. Bayless & Roberts, Inc., 608 P.2d 281, 295 (Alaska 1980) (by statute); Mayhew v. Berrien County Road Commission, 414 Mich. 399, 410 , 326 N.W.2d 366, 370-71 (1982) (by statute); Bradley v. Appalachian Power Co., 163 W.Va. 332 , 256 S.E.2d 879, 886-87 (1979) (by judicial decision). 1984See, e.g., Continental Insurance Co. v. Bayless & Roberts, Inc., 608 P.2d 281, 295 (Alaska 1980) (by statute); Mayhew v. Berrien County Road Commission, 414 Mich. 399, 410 , 326 N.W.2d 366, 370-71 (1982) (by statute); Bradley v. Appalachian Power Co., 163 W.Va. 332 , 256 S.E.2d 879, 886-87 (1979) (by judicial decision). | 1 | 1 |
Continental Insurance Co. v. Bayless & Roberts, Inc.green1 sentence1984See, e.g., Continental Insurance Co. v. Bayless & Roberts, Inc., 608 P.2d 281, 295 (Alaska 1980) (by statute); Mayhew v. Berrien County Road Commission, 414 Mich. 399, 410 , 326 N.W.2d 366, 370-71 (1982) (by statute); Bradley v. Appalachian Power Co., 163 W.Va. 332 , 256 S.E.2d 879, 886-87 (1979) (by judicial decision). | 1 | 1 |
Mayhew v. Berrien County Road Commissiongreen2 sentences1984See, e.g., Continental Insurance Co. v. Bayless & Roberts, Inc., 608 P.2d 281, 295 (Alaska 1980) (by statute); Mayhew v. Berrien County Road Commission, 414 Mich. 399, 410 , 326 N.W.2d 366, 370-71 (1982) (by statute); Bradley v. Appalachian Power Co., 163 W.Va. 332 , 256 S.E.2d 879, 886-87 (1979) (by judicial decision). 1984See, e.g., Continental Insurance Co. v. Bayless & Roberts, Inc., 608 P.2d 281, 295 (Alaska 1980) (by statute); Mayhew v. Berrien County Road Commission, 414 Mich. 399, 410 , 326 N.W.2d 366, 370-71 (1982) (by statute); Bradley v. Appalachian Power Co., 163 W.Va. 332 , 256 S.E.2d 879, 886-87 (1979) (by judicial decision). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Ezzone v. Riccardi
green
1 sentence1999In other words, Revere would interpret the phrase “all payments in settlement of a claim,” see Ezzone, 525 N.W.2d at 401 , to mean one claim, distinguishable from other types of claims. | 1 | 1999–1999 |
Goetzman v. Wichern
green
1 sentence1985In that case the supreme court held that the pro tanto credit rule is applicable in comparative negligence cases controlled by the principles set forth in Goetzman v. Wichern, 327 N.W.2d 742 (Iowa 1983). | 1 | 1985–1985 |
Theobald v. Angelos
green
2 sentences1981She submits two alternative methods of allowing credit against recovery: (1) that we adopt the result reached by the New Jersey Supreme Court in Theobald v. Angelos, 44 N.J. 228 , 208 A.2d 129 (1965), in which the pro tanto rule was rejected in favor of a pro rata credit; or (2) that a hearing be conducted to determine what portion of the settlement was intended by the parties to be compensation for damages and what portion was paid by the settling tortfeasors to purchase “peace” (e. g., to place a limit on the tortfeasor’s liability, to avoid litigation expense, etc.), and that only the porti 1981She submits two alternative methods of allowing credit against recovery: (1) that we adopt the result reached by the New Jersey Supreme Court in Theobald v. Angelos, 44 N.J. 228 , 208 A.2d 129 (1965), in which the pro tanto rule was rejected in favor of a pro rata credit; or (2) that a hearing be conducted to determine what portion of the settlement was intended by the parties to be compensation for damages and what portion was paid by the settling tortfeasors to purchase “peace” (e. g., to place a limit on the tortfeasor’s liability, to avoid litigation expense, etc.), and that only the porti | 1 | 1981–1981 |
Community School District of Postville v. Gordon N. Peterson, Inc.
green
2 sentences1981In support of her position, she cites Community School District v. Gordon N. Peterson, Inc., 176 N.W.2d 169 (Iowa 1970), in which, she maintains, this court abandoned the common law’s artificial and mechanical treatment of releases. 1981Furthermore, in that case we reiterated the theory underlying the pro tanto credit rule: “No double recovery will be tolerated.” Id. | 1 | 1981–1981 |
Schnebly Ex Rel. Schnebly v. Baker
green
1 sentence1981Wadle nevertheless contends that this court implicitly adopted the pro rata credit rule she advocates in Schnebly v. Baker, 221 N.W.2d 739 (Iowa 1974) (Schnebly II) (per curiam). | 1 | 1981–1981 |
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.