Iowa Code

Iowa Code § 461C.3 (2026)

Liability of holder limited

✓ current as of July 2026

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1. Except as specifically recognized by or provided in section 461C.6, a holder of land does not owe a duty of care to keep the premises safe for entry or use by others for a recreational purpose or urban deer control, or to give any warning of a dangerous condition, use, structure, or activity on such premises to persons entering for such purposes.

2. Except as specifically recognized by or provided in section 461C.6, a holder of land does not owe a duty of care to others solely because the holder is guiding, directing, supervising, or participating in any recreational purpose or urban deer control undertaken by others on the holder’s land. [C71, 73, 75, 77, 79, 81, §111C.3] C93, §461C.3 2006 Acts, ch 1121, §4; 2013 Acts, ch 128, §3; 2013 Acts, ch 140, §29, 39 Referred to in §461C.5 \n

Notes of Decisions

Cited in 3 cases (2 in the last 5 years), 2013–2025 · leading case: Kimberly Ann Sallee, Individually & as Next Friend of Lucas Gregory Durkop & Maria Christina Rivera, Matthew James Sallee, & James Allan Sallee v. Matthew R. Stewart & Diana Stewart D/B/A Stewartland Holsteins, 827 N.W.2d 128 (Iowa 2013).

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Kimberly Ann Sallee, Individually & as Next Friend of Lucas Gregory Durkop & Maria Christina Rivera, Matthew James Sallee, & James Allan Sallee v. Matthew R. Stewart & Diana Stewart D/B/A Stewartland Holsteins, 827 N.W.2d 128 (Iowa 2013). · cites it 49× “” Iowa Code § 461C.3 (2009). Surely we all recognize this as classic premises liability language.”

Est. of Sharon Kahn & Suzanne L. Rowe, as Adm'r of The Est. of Sharon Kahn, & Est. Of Vicki Hodges & Suzanne L. Rowe & Sierra D. Reyes, as Co-Administrators of the Est. of Vicki Hodges v. City of Clermont, Iowa, Fayette Cnty. Conservation Bd., Fayette Cnty., Iowa, & State of Iowa (Iowa 2025). · cites it 3× “” With this definition in hand, the State then points to Iowa Code § 461C.3(1), which states that “a holder of land does not owe a duty of care to keep the premises safe for entry or use by others for a recreational purpose .”

Breitenstein v. Peterson (Iowa Ct. App. 2025). “The statutes mandate that “[t]he provisions of this chapter shall be construed liberally and broadly in favor of private holders of land to accomplish the purposes of this chapter.”

— Iowa Code § 461C.3(1) — 2 cases

Est. of Sharon Kahn & Suzanne L. Rowe, as Adm'r of The Est. of Sharon Kahn, & Est. Of Vicki Hodges & Suzanne L. Rowe & Sierra D. Reyes, as Co-Administrators of the Est. of Vicki Hodges v. City of Clermont, Iowa, Fayette Cnty. Conservation Bd., Fayette Cnty., Iowa, & State of Iowa (Iowa 2025). “” With this definition in hand, the State then points to Iowa Code § 461C.3(1), which states that “a holder of land does not owe a duty of care to keep the premises safe for entry or use by others for a recreational purpose .”

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