11 Iowa opinions name it 1 courts 1944–2025 4 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 |
|---|---|---|
Lloyd v. Stategreen2 sentences2025Even after the ITCA’s enactment, immunity “remains the rule rather than the exception.” Wagner, 952 N.W.2d at 856 (quoting Lloyd v. State, 251 N.W.2d 551, 555 (Iowa 1977)). 2025Even after the ITCA’s enactment, immunity “remains the rule rather than the exception.” Wagner, 952 N.W.2d at 856 (quoting Lloyd v. State, 251 N.W.2d 551, 555 (Iowa 1977)). | 5 | 6 |
Wallace v. Wellsgreen2 sentences2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) 2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) | 3 | 3 |
Fowler v. Baalmann, Inc.green2 sentences2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i 2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i | 3 | 3 |
France v. Munsongreen2 sentences2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) 2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) | 3 | 3 |
McDonald v. Seaygreen2 sentences2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i 2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i | 3 | 3 |
Claim of Adams v. Rossgreen2 sentences2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i 2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i | 3 | 3 |
Mathers v. Sellersgreen2 sentences2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) 2017Ct. 1947) (“[W]hen the statutory number of persons is employed most of the time so that it can be said to be the rule rather than the exception; or where . . . the event or condition requiring their employment is a regularly recurring one in the ordinary course of the business, the employer is within the Act.” (Citation omitted.)); Wallace v. Wells, 255 S.W.2d 970, 973 (Ark. 1953) (noting employer “had five men regularly employed, although some of them worked only two days a week”); France v. Munson, 3 A.2d 78, 81 (Conn. 1938) (“The word ‘regularly’ implies a practice [of employment] . . . .”) | 3 | 3 |
Cotman v. Greengreen2 sentences2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i 2017Ct. App. 1959) (“It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed . . . .”); McDonald v. Seay, 8 S.E.2d 796, 797 (Ga. 1940) (concluding employer within purview of Act when “employer . . . testified that it was his custom or plan of operation to work as many as twelve men thirty per cent. [sic] of the time”); Fowler v. Baalmann, Inc., 234 S.W.2d 11, 14 (Mo. 1950) (en banc) (“And ‘regularly’ as used in the statute ‘refers to the question whether the occurrence i | 3 | 3 |
Swanger v. Stategreen2 sentences2025The state and its employees “may now be sued in tort, but only in the manner and to the extent to which consent has been given by the legislature.” Swanger v. State, 445 N.W.2d 344, 346 (Iowa 1989); see also Segura v. State, 889 N.W.2d 215, 221 (Iowa 2017) (“By enacting the ITCA, the State waived this immunity and opened itself to suit, but it did so strictly on its terms.”). 2025The state and its employees “may now be sued in tort, but only in the manner and to the extent to which consent has been given by the legislature.” Swanger v. State, 445 N.W.2d 344, 346 (Iowa 1989); see also Segura v. State, 889 N.W.2d 215, 221 (Iowa 2017) (“By enacting the ITCA, the State waived this immunity and opened itself to suit, but it did so strictly on its terms.”). | 2 | 2 |
Paula Segura and Ricardo Segura v. State of Iowagreen2 sentences2025The state and its employees “may now be sued in tort, but only in the manner and to the extent to which consent has been given by the legislature.” Swanger v. State, 445 N.W.2d 344, 346 (Iowa 1989); see also Segura v. State, 889 N.W.2d 215, 221 (Iowa 2017) (“By enacting the ITCA, the State waived this immunity and opened itself to suit, but it did so strictly on its terms.”). 2025The state and its employees “may now be sued in tort, but only in the manner and to the extent to which consent has been given by the legislature.” Swanger v. State, 445 N.W.2d 344, 346 (Iowa 1989); see also Segura v. State, 889 N.W.2d 215, 221 (Iowa 2017) (“By enacting the ITCA, the State waived this immunity and opened itself to suit, but it did so strictly on its terms.”). | 2 | 2 |
MH by and Through Callahan v. Stategreen2 sentences2024M.H. v. State, 385 N.W.2d 533, 538 (Iowa 1986) (discussing the “removal of immunity from suit”). 2024M.H. v. State, 385 N.W.2d 533, 538 (Iowa 1986) (discussing the “removal of immunity from suit”). | 2 | 2 |
Nixon v. Stategreen2 sentences2024See Anderson v. State, 2 N.W.3d 807, 812 (Iowa 2024); Wagner v. State, 952 N.W.2d 843 , 856 (Iowa 2020) (“The immunity of the State is from suit rather than from liability and remains the rule rather than the exception.” (quoting Lloyd v. State, 6 251 N.W.2d 551, 555 (Iowa 1977))); Lee v. State, 874 N.W.2d 631 , 637–38 (Iowa 2016) (stating the “principle of state sovereign immunity . . . recognizes that inherent in the nature of sovereignty is some degree of immunity from suit”); Nixon v. State, 704 N.W.2d 643, 645 (Iowa 2005) (stating the State “was immune from suit under the common-law doctr 2024See Anderson v. State, 2 N.W.3d 807, 812 (Iowa 2024); Wagner v. State, 952 N.W.2d 843 , 856 (Iowa 2020) (“The immunity of the State is from suit rather than from liability and remains the rule rather than the exception.” (quoting Lloyd v. State, 6 251 N.W.2d 551, 555 (Iowa 1977))); Lee v. State, 874 N.W.2d 631 , 637–38 (Iowa 2016) (stating the “principle of state sovereign immunity . . . recognizes that inherent in the nature of sovereignty is some degree of immunity from suit”); Nixon v. State, 704 N.W.2d 643, 645 (Iowa 2005) (stating the State “was immune from suit under the common-law doctr | 2 | 2 |
Gartin v. Jefferson Countygreen1 sentence2020“Claims which are outside the scope of the waiver must be denied.” Gartin v. Jefferson Cnty., 281 N.W.2d 25, 26 (Iowa Ct. App. 1979). “[Until the ITCA was enacted], tort suits could not be brought against the state because such suits were prohibited by the doctrine of sovereign immunity. | 1 | 1 |
Hunter v. . Peirsongreen2 sentences2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth 2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth | 1 | 1 |
Johnson v. Asheville Hosiery Co.green2 sentences2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth 2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth | 1 | 1 |
Cauchon v. Gladstonegreen2 sentences2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth 2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth | 1 | 1 |
Lacroix v. Frechettegreen2 sentences2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth 2017Ct. App. 1959) ("It is also the general rule that coverage is imposed where there is uniformity of practice in the particular business of the employer and the requisite number of employees are employed...."); McDonald v. Seay, 62 Ga.Ct.App. 519, 8 S.E.2d 796, 797 (1940) (concluding employer within purview of Act when "employer ... testified that it was his custom or plan of operation to work as many as twelve men thirty per cent, [sic] of the time”); Fowler v. Baalmann, Inc., 361 Mo. 204 , 234 S.W.2d 11, 14 (1950) (en banc) ("And 'regularly' as used in the statute 'refers to the question wheth | 1 | 1 |
Hubbard v. Stategreen1 sentence1977See in support of the foregoing statements Hubbard v. State, 163 N.W.2d 904 (Iowa 1969). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Drahaus v. Stategreen1 sentence2024Although the State is no longer wholly immune from tort suits, the State may be sued “only in the manner and to the extent to which consent has been given by the legislature.” Swanger v. State, 445 N.W.2d 344, 346 (Iowa 1989); see also Segura v. State, 889 N.W.2d 215, 221 (Iowa 2017) (“By enacting the ITCA, the State waived this immunity and opened itself to suit, but it did so strictly on its terms.”); Drahaus v. State, 584 N.W.2d 270, 272 (Iowa 1998) (“Thus, a private citizen’s right of suit under the Tort Claims Act is not absolute, but rather is limited by conditions set forth by the legis | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Tina Elizabeth Lee v. State of Iowa and Polk County Clerk of Court
green
2 sentences2024See Anderson v. State, 2 N.W.3d 807, 812 (Iowa 2024); Wagner v. State, 952 N.W.2d 843 , 856 (Iowa 2020) (“The immunity of the State is from suit rather than from liability and remains the rule rather than the exception.” (quoting Lloyd v. State, 6 251 N.W.2d 551, 555 (Iowa 1977))); Lee v. State, 874 N.W.2d 631 , 637–38 (Iowa 2016) (stating the “principle of state sovereign immunity . . . recognizes that inherent in the nature of sovereignty is some degree of immunity from suit”); Nixon v. State, 704 N.W.2d 643, 645 (Iowa 2005) (stating the State “was immune from suit under the common-law doctr 2024See Anderson v. State, 2 N.W.3d 807, 812 (Iowa 2024); Wagner v. State, 952 N.W.2d 843 , 856 (Iowa 2020) (“The immunity of the State is from suit rather than from liability and remains the rule rather than the exception.” (quoting Lloyd v. State, 6 251 N.W.2d 551, 555 (Iowa 1977))); Lee v. State, 874 N.W.2d 631 , 637–38 (Iowa 2016) (stating the “principle of state sovereign immunity . . . recognizes that inherent in the nature of sovereignty is some degree of immunity from suit”); Nixon v. State, 704 N.W.2d 643, 645 (Iowa 2005) (stating the State “was immune from suit under the common-law doctr | 2 | 2024–2024 |
Eddington v. Northwestern Bell Telephone Co.
green
2 sentences1944Co., 201 Iowa 67 , 202 N. W. 374 . 1944Co., 201 Iowa 67 , 202 N. W. 374 . | 1 | 1944–1944 |
National Cast Iron Pipe Co. v. Higginbotham
green
2 sentences1944In construing the corresponding- section and exception in the Alabama Compensation Act, the court, in National Cast Iron Pipe Co. v. Higginbotham, 216 Ala. 129, 132 , 112 So. 734, 736 , said: “If there is doubt about an exception or provino in such a statute it must be judged on the assumption that the rule is broader than the exception, and all doubts and implications should be resolved in favor of the rule rather than the exception; that is to say, the latter is strictly construed when it is to modify or qualify comprehensive terms of an enactment. ’ ’ Citing Alabama cases and Eddington v. N 1944In construing the corresponding- section and exception in the Alabama Compensation Act, the court, in National Cast Iron Pipe Co. v. Higginbotham, 216 Ala. 129, 132 , 112 So. 734, 736 , said: “If there is doubt about an exception or provino in such a statute it must be judged on the assumption that the rule is broader than the exception, and all doubts and implications should be resolved in favor of the rule rather than the exception; that is to say, the latter is strictly construed when it is to modify or qualify comprehensive terms of an enactment. ’ ’ Citing Alabama cases and Eddington v. N | 1 | 1944–1944 |
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.
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.