relaxed standard (Iowa) · Go Syfert
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relaxed standard in Iowa

9 Iowa opinions name it 2 courts 1996–2025 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.

Followed or applied (4)

CaseFollowedCited
Brede v. Koopgreen
iowa · 2005 · cited in 2 Iowa opinions naming this issue, 2015–2025
2 sentences

2025“Prescriptive easements based on this relaxed standard ‘are determined either on the theory of a valid executed oral agreement or on the principle of estoppel.’” Brede, 706 N.W.2d at 827 (citation omitted).

2015Prescriptive easements based on this relaxed standard “are determined either on the theory of a valid executed oral agreement or on the principle of estoppel.” Id. 11 Under this exception to the strict rules governing prescriptive easements, an easement by prescription may arise “in those instances in which the original entry upon the lands of another is under an oral agreement or express consent of the servient owner and the party claiming the easement expends substantial money or labor to promote the claimed use in reliance upon the consent or as consideration for the agreement.” Brede v. Ko

22
Simonsen v. Toddgreen
iowa · 1967 · cited in 3 Iowa opinions naming this issue, 2005–2015
2 sentences

2015Prescriptive easements based on this relaxed standard “are determined either on the theory of a valid executed oral agreement or on the principle of estoppel.” Id. 11 Under this exception to the strict rules governing prescriptive easements, an easement by prescription may arise “in those instances in which the original entry upon the lands of another is under an oral agreement or express consent of the servient owner and the party claiming the easement expends substantial money or labor to promote the claimed use in reliance upon the consent or as consideration for the agreement.” Brede v. Ko

2015Prescriptive easements based on this relaxed standard “are determined either on the theory of a valid executed oral agreement or on the principle of estoppel.” Id. 11 Under this exception to the strict rules governing prescriptive easements, an easement by prescription may arise “in those instances in which the original entry upon the lands of another is under an oral agreement or express consent of the servient owner and the party claiming the easement expends substantial money or labor to promote the claimed use in reliance upon the consent or as consideration for the agreement.” Brede v. Ko

13
State v. Groffgreen
iowa · 1982 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024See Groff, 323 N.W.2d at 208 .

11
Donald D. Fletcher v. Union Pacific Railroad Company, a Corporationgreen
ca8 · 1980 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016The test “is simply whether the proofs justify with reason the conclusion that employer negligence played any part, even the slightest, in producing the injury or death for which damages are sought.” Id.; accord Fletcher, 621 F.2d at 909 (“The test of causation under the FELA is whether the railroad’s negligence played any part, however small, in the injury which is the subject of the suit.”).

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 (4)

CaseCitedYears
CSX Transportation, Inc. v. McBride green
scotus · 2011
2 sentences

2025The Court found support for its broad reading directly from Gottshall: “Given the breadth of the phrase ‘resulting in whole or in part from the [railroad’s] negligence,’ and Congress’ ‘humanitarian’ and ‘remedial goal[s],’ we have recognized that, in comparison to tort litigation at common law, ‘a relaxed standard of causation applies under FELA.’ ” Id. at 691–92 (alteration in original) (quoting Gottshall, 512 U.S. at 542–43).

2025The Court found support for its broad reading directly from Gottshall: “Given the breadth of the phrase ‘resulting in whole or in part from the [railroad’s] negligence,’ and Congress’ ‘humanitarian’ and ‘remedial goal[s],’ we have recognized that, in comparison to tort litigation at common law, ‘a relaxed standard of causation applies under FELA.’ ” Id. at 691–92 (alteration in original) (quoting Gottshall, 512 U.S. at 542–43).

32016–2025
Consolidated Rail Corporation v. Gottshall green
scotus · 1994
2 sentences

2025The Court found support for its broad reading directly from Gottshall: “Given the breadth of the phrase ‘resulting in whole or in part from the [railroad’s] negligence,’ and Congress’ ‘humanitarian’ and ‘remedial goal[s],’ we have recognized that, in comparison to tort litigation at common law, ‘a relaxed standard of causation applies under FELA.’ ” Id. at 691–92 (alteration in original) (quoting Gottshall, 512 U.S. at 542–43).

2025The Court found support for its broad reading directly from Gottshall: “Given the breadth of the phrase ‘resulting in whole or in part from the [railroad’s] negligence,’ and Congress’ ‘humanitarian’ and ‘remedial goal[s],’ we have recognized that, in comparison to tort litigation at common law, ‘a relaxed standard of causation applies under FELA.’ ” Id. at 691–92 (alteration in original) (quoting Gottshall, 512 U.S. at 542–43).

22025–2025
State Farm Mutual Automobile Insurance Co. v. Matlock green
tex · 1970
1 sentence

1996Schmid, 288 N.Y.S.2d at 825 ; Matlock, 462 S.W.2d at 278 ; see, e.g., Valdes v. Prudence Mut.

11996–1996
In re the Arbitration between Merchants Mutual Insurance & Schmid green
nysupct · 1968
1 sentence

1996Schmid, 288 N.Y.S.2d at 825 ; Matlock, 462 S.W.2d at 278 ; see, e.g., Valdes v. Prudence Mut.

11996–1996

Where else courts name it

PA 219 (1958–2026) IL 50 (1976–2025) TX 36 (1970–2025) NJ 35 (1975–2026) NY 34 (1877–2024) CA 28 (1960–2025) FL 26 (1991–2019) WA 23 (1994–2024) LA 22 (1965–2025) OH 16 (1989–2023) CT 15 (1973–2016) IN 15 (1883–2020) WI 14 (1926–2020) MD 13 (1928–2020) TN 13 (1994–2017) KS 12 (1990–2016) GA 12 (1988–2017) OK 11 (1935–2014) RI 11 (1989–2006) ID 9 (1977–2024) IA 9 (1996–2025) KY 8 (1956–2015) UT 7 (1981–2021) VA 7 (2006–2025) CO 6 (1983–2020) AL 6 (1989–2016) NM 6 (1989–2020) MS 6 (1997–2012) MI 5 (1990–2019) MA 5 (1980–2009) MO 5 (1975–2023) AZ 5 (1985–2021) SC 5 (2000–2018) AK 4 (1985–2004) DC 4 (2000–2022) MN 4 (2014–2018) VT 3 (1998–2020) OR 3 (1990–2024) NV 3 (1990–2016) NC 3 (1995–2004) HI 3 (2002–2016) ND 2 (1986–1994) DE 2 (1980–2002) MT 2 (2015–2015) AR 2 (1985–2023)

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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