Iowa Code

Iowa Code § 490.1430 (2026)

Grounds for judicial dissolution

✓ current as of July 2026
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1. The district court may dissolve a corporation in any of the following ways: a. A proceeding by the attorney general if it is established that any of the following apply: (1) The corporation obtained its articles of incorporation through fraud. (2) The corporation has continued to exceed or abuse the authority conferred upon it by law. b. A proceeding by a shareholder if it is established that any of the following conditions exist: (1) The directors are deadlocked in the management of the corporate affairs, the shareholders are unable to break the deadlock, and irreparable injury to the corporation is threatened or being suffered, or the business and affairs of the corporation can no longer be conducted to the advantage of the shareholders generally, because of the deadlock. (2) The directors or those in control of the corporation have acted, are acting, or will act in a manner that is illegal, oppressive, or fraudulent.\n\nTue Dec 09 22:07:44 2025 Iowa Code 2026, Chapter 490 (142, 1) 121 BUSINESS CORPORATIONS, §490.1432\n\n (3) The shareholders are deadlocked in voting power and have failed, for a period that includes at least two consecutive annual meeting dates, to elect successors to directors whose terms have expired. (4) The corporate assets are being misapplied or wasted. c. A proceeding by a creditor if it is established that any of the following applies: (1) The creditor’s claim has been reduced to judgment, the execution on the judgment returned unsatisfied, and the corporation is insolvent. (2) The corporation has admitted in writing that the creditor’s claim is due and owing and the corporation is insolvent. d. A proceeding by the corporation to have its voluntary dissolution continued under court supervision. e. A proceeding by a shareholder if the corporation has abandoned its business and has failed within a reasonable time to liquidate and distribute its assets and dissolve. 2. Subsection 1, paragraph “b”, shall not apply in the case of a corporation that, on the date of the filing of the proceeding, has a class or series of shares which is any of the following: a. A covered security under section 18(b)(1)(A) or (B) of the federal Securities Act of 1933. b. Not a covered security, but is held by at least three hundred shareholders and the shares outstanding have a market value of at least twenty million dollars, exclusive of the value of such shares held by the corporation’s subsidiaries, senior executives, directors, and if they own more than ten percent of such shares, beneficial shareholders, and voting trust beneficial owners. 3. a. As used in subsection 1, “shareholder” means a record shareholder, a beneficial shareholder, and an unrestricted voting trust beneficial owner. b. As used in subsection 2, “shareholder” means a record shareholder, a beneficial shareholder, and a voting trust beneficial owner. 89 Acts, ch 288, §156; 2013 Acts, ch 31, §68, 82; 2021 Acts, ch 165, §182, 230 Referred to in §490.304, 490.1431, 490.1433, 490.1434

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Notes of Decisions
Cited in 14 cases (5 in the last 5 years), 2000–2026 · leading case: John R. Baur v. Baur Farms, Inc. & Robert F. Baur, 832 N.W.2d 663 (Iowa 2013).
John R. Baur v. Baur Farms, Inc. & Robert F. Baur, 832 N.W.2d 663 (Iowa 2013). · cites it 6× “” Iowa Code § 490.1430 (2)(6) (2011). The IBCA, however, offers no definition of “oppressive” or “oppression,” and the Model Business Corporation Act, on which the IBCA is based, likewise fails to furnish definitions of these terms.”
Lee C. Ritchie v. Ann Caldwell Rupe, as Tr. for the Dallas Gordon Rupe, III 1995 Fam. Trust, 443 S.W.3d 856 (Tex. 2014). “55; Iowa Code § 490.1430 ; Md.Code, Corps. & Ass’ns § 3-413; Mich.”
Scott v. Trans-Sys., Inc., 64 P.3d 1 (Wash. 2003). “For example, TSI could have been required to produce an accounting of the money it loaned to Northwest and the interest it would have charged as compared to the interest paid by Northwest on the line of credit used by TSI.”
Scott v. Trans-Sys., Inc., 148 Wash. 2d 701 (Wash. 2003). “For example, TSI could have been required to produce an accounting of the money it loaned to Northwest and the interest it would have charged as compared to the interest paid by Northwest on the line of credit used by TSI.”
In Re Quad City Minority Broadcasters, Inc., 252 B.R. 773 (Bankr. S.D. Iowa 2000). · cites it 6× “Finally, although Iowa Code § 490.1430 (4) provides a method for a creditor to initiate state judicial action to dissolve and to liquidate a corporation or to continue a voluntary dissolution by state judicial means, 6 the statute does not forbid federal bankruptcy relief.”
Goettsch v. Goettsch, 29 F. Supp. 3d 1231 (N.D. Iowa 2014). · cites it 9× “In Count One, the plaintiffs seek a judicially-ordered dissolution of Circle G under Iowa Code § 490.1430 , a mandatory buyout under Iowa Code § 490.”
Janet Walker & Linda Martens v. Marlin Daniels, Glenn Daniels, & David Daniels, each in their capacity as Co-Executors of the Est. of Lucille Daniels, & individually, Est. of Lucille Daniels, & Daniels, Inc. (Iowa Ct. App. 2024). · cites it 29× “under Iowa Code section 490.1430 for the first time. They alleged that dissolution was warranted under that statute because the brothers “as directors and officers in control of the Company, have acted and continue to act in a manner that is illegal, oppressive and/or fraudulent…”
Susan A. Guge & Peggy McDonald v. Kassel Enter., Inc. (Iowa 2021). · cites it 13× “See Iowa Code § 490.1430 (1)(b)(4) (referencing “corporate assets .”
John R. Baur v. Baur Farms, Inc., & Robert F. Baur (Iowa Ct. App. 2016). · cites it 4× “BFI did not respond to his offer, and on October 10, 2007, Jack filed an action seeking dissolution of the corporation under Iowa Code section 490.1430 (2007), based on a claim of oppressive conduct.”
Guge v. Kassel Enter., Inc. (Iowa Ct. App. 2022). · cites it 4× “Count I of the lawsuit sought judicial dissolution of Kassel Enterprises under Iowa Code 3 section 490.1430(1)(b)(2) (2018) (for “illegal, oppressive, or fraudulent” conduct) and section 490.”
Gregory Herrick & Jane Evans v. 21st Century Farms, LTD., & Thomas W. Evans & George J. Evans, Individually (Iowa Ct. App. 2026). · cites it 4× “They alleged minority shareholder oppression and breach of fiduciary duty and requested judicial 5 dissolution of the corporation under Iowa Code section 490.1430 (2023). Trial occurred one year later.”
William Van Horn & June Lindner v. R.H. Van Horn Farms, Inc., Robert H. Van Horn a/k/a Robert Van Horn a/k/a R.H. Van Horn & John Van Horn, 919 N.W.2d 768 (Iowa Ct. App. 2018). · cites it 2× “Oppression Siblings June and William contend they suffered minority-shareholder oppression by the acts of their father, R.”
— Iowa Code § 490.1430(1) — 1 case
Janet Walker & Linda Martens v. Marlin Daniels, Glenn Daniels, & David Daniels, each in their capacity as Co-Executors of the Est. of Lucille Daniels, & individually, Est. of Lucille Daniels, & Daniels, Inc. (Iowa Ct. App. 2024). “under Iowa Code section 490.1430 for the first time. They alleged that dissolution was warranted under that statute because the brothers “as directors and officers in control of the Company, have acted and continue to act in a manner that is illegal, oppressive and/or fraudulent…”
— Iowa Code § 490.1430(1)(b) — 1 case
Janet Walker & Linda Martens v. Marlin Daniels, Glenn Daniels, & David Daniels, each in their capacity as Co-Executors of the Est. of Lucille Daniels, & individually, Est. of Lucille Daniels, & Daniels, Inc. (Iowa Ct. App. 2024). “under Iowa Code section 490.1430 for the first time. They alleged that dissolution was warranted under that statute because the brothers “as directors and officers in control of the Company, have acted and continue to act in a manner that is illegal, oppressive and/or fraudulent…”
— Iowa Code § 490.1430(1)(b)(2) — 4 cases
Susan A. Guge & Peggy McDonald v. Kassel Enter., Inc. (Iowa 2021). “See Iowa Code § 490.1430 (1)(b)(4) (referencing “corporate assets .”
William Van Horn & June Lindner v. R.H. Van Horn Farms, Inc., Robert H. Van Horn a/k/a Robert Van Horn a/k/a R.H. Van Horn & John Van Horn, 919 N.W.2d 768 (Iowa Ct. App. 2018). “Oppression Siblings June and William contend they suffered minority-shareholder oppression by the acts of their father, R.”
Guge v. Kassel Enter., Inc. (Iowa Ct. App. 2022). “Count I of the lawsuit sought judicial dissolution of Kassel Enterprises under Iowa Code 3 section 490.1430(1)(b)(2) (2018) (for “illegal, oppressive, or fraudulent” conduct) and section 490.”
Gregory Herrick & Jane Evans v. 21st Century Farms, LTD., & Thomas W. Evans & George J. Evans, Individually (Iowa Ct. App. 2026). “They alleged minority shareholder oppression and breach of fiduciary duty and requested judicial 5 dissolution of the corporation under Iowa Code section 490.1430 (2023). Trial occurred one year later.”
— Iowa Code § 490.1430(1)(b)(4) — 2 cases
Susan A. Guge & Peggy McDonald v. Kassel Enter., Inc. (Iowa 2021). “See Iowa Code § 490.1430 (1)(b)(4) (referencing “corporate assets .”
Guge v. Kassel Enter., Inc. (Iowa Ct. App. 2022). “Count I of the lawsuit sought judicial dissolution of Kassel Enterprises under Iowa Code 3 section 490.1430(1)(b)(2) (2018) (for “illegal, oppressive, or fraudulent” conduct) and section 490.”
— Iowa Code § 490.1430(2) — 1 case
John R. Baur v. Baur Farms, Inc. & Robert F. Baur, 832 N.W.2d 663 (Iowa 2013). “” Iowa Code § 490.1430 (2)(6) (2011). The IBCA, however, offers no definition of “oppressive” or “oppression,” and the Model Business Corporation Act, on which the IBCA is based, likewise fails to furnish definitions of these terms.”
— Iowa Code § 490.1430(2)(b) — 1 case
John R. Baur v. Baur Farms, Inc., & Robert F. Baur (Iowa Ct. App. 2016). “BFI did not respond to his offer, and on October 10, 2007, Jack filed an action seeking dissolution of the corporation under Iowa Code section 490.1430 (2007), based on a claim of oppressive conduct.”
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