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Iowa Code

Iowa Code § 20.28 (2026)

Inconsistent statutes — effect

✓ Iowa Code 2026 (laws through the 2025 session)
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A provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement which is made final under this chapter shall supersede the term or condition of the collective bargaining agreement unless otherwise provided by the general assembly. A provision of a proposed collective bargaining agreement negotiated according to this chapter which conflicts with the Code shall not become a provision of the final collective bargaining agreement until the general assembly has amended the Code to remove the conflict. [C79, 81, §20.28]

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Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1982–2022 · leading case: Lockhart v. Cedar Rapids Cmty. Sch. Dist., 963 F. Supp. 805 (N.D. Iowa 1997).
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Lockhart v. Cedar Rapids Cmty. Sch. Dist., 963 F. Supp. 805 (N.D. Iowa 1997). · cites it 6× “652(7) is clearly dispelled by Iowa Code § 20.28 . Section 20.28 provides that [a provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement .”
Shenandoah Educ. Ass'n v. Shenandoah Cmty. Sch. Dist., 337 N.W.2d 477 (Iowa 1983). · cites it 8× “Iowa Code § 20.28 (emphasis added). The use of the word "shall" indicates that such deference is mandatory.”
Norton v. Adair Cnty., 441 N.W.2d 347 (Iowa 1989). · cites it 4× “652(7) is clearly dispelled by Iowa Code section 20.28. Section 20.28 provides that [ a] provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement .”
Iowa City Cmty. Sch. Dist. v. Iowa City Educ. Ass'n, 343 N.W.2d 139 (Iowa 1983). · cites it 4× “The reserved contractual right of the school district "to withhold salary increases for unsatisfactory performance" is nothing more than a recognition of this concept, and in light of section 20.”
City of Mason City v. Pub. Emp. Relations Bd., 316 N.W.2d 851 (Iowa 1982). · cites it 4× “[5] Similar in effect to the Pennsylvania statute is section 20.28, The Code, which provides in part: "A provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement which is made final under this chapter shall supersede the term or…”
Stammeyer v. Div. of Narcotics Enf't of the Iowa Dep't of Pub. Saf., 721 N.W.2d 541 (Iowa 2006). · cites it 2× “Section 20.28 provides: A provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement which is made final under this chapter shall supersede the term or condition of the collective bargaining agreement unless otherwise provided by…”
Polk Cnty. Secondary Roads v. Iowa Civil Rights Comm'n, 468 N.W.2d 811 (Iowa 1991). · cites it 2× “Iowa Code § 20.28 . The Court of Appeals of New York faced a similar situation involving Title VII of the Civil Rights Act of 1964, 42 U.”
Waterloo Educ. Ass'n v. Waterloo Cmty. Sch. Dist., 372 N.W.2d 267 (Iowa 1985). · cites it 4× “We also note that section 20.28 of the Code provides: A provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement which is made final under this chapter shall supersede the term or condition of the collective bargaining agreement…”
Devine v. City of Des Moines, 366 N.W.2d 580 (Iowa 1985). · cites it 2× “See Iowa Code § 20.28 (Iowa Code prevails where it is inconsistent with collective bargaining agreement).”
Moore v. Davenport Civil Serv. Comm'n, 790 N.W.2d 809 (Iowa Ct. App. 2010). · cites it 2× “Section 20.28 provides: A provision of the Code which is inconsistent with any term or condition of a collective bargaining agreement which is made final under this chapter shall supersede the term or condition of the collective bargaining agreement unless otherwise provided by…”
Waterloo Police Prot. Ass'n v. Pub. Emp. Relations Bd., 497 N.W.2d 833 (Iowa 1993). · cites it 4× “We first consider the City's contention that liability insurance against punitive damages is not a topic of mandatory bargaining under section 20.9. We have previously espoused a two-prong test in considering questions of this nature.”
State v. AFSCME Iowa Council 61, 648 N.W.2d 119 (Iowa 2002). · cites it 8× “Iowa Code § 20.28 . The State urges that under Iowa Code section 20.”
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