Iowa Code
Iowa Code § 516.1 (2026)
Inurement of policy
✓ current as of July 2026
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All policies insuring the legal liability of the insured, issued in this state by any company, association or reciprocal exchange shall, notwithstanding any other provision of the statutes, contain a provision providing that, in event an execution on a judgment against the insured be returned unsatisfied in an action by a person who is injured or whose property is damaged, the judgment creditor shall have a right of action against the insurer to the same extent that such insured could have enforced the insured’s claim against such insurer had such insured paid such judgment. [C35, §9024-g1; C39, §9024.1; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §516.1]
\nNotes of Decisions
Cited in 38
cases (4 in the last 5 years), 1952–2025 · leading case: Red Giant Oil Co. v. Lawlor, 528 N.W.2d 524 (Iowa 1995).
Red Giant Oil Co. v. Lawlor, 528 N.W.2d 524 (Iowa 1995). “See Iowa Code § 516.1 (1991) (permitting such an action in event an execution on a judgment against insured is returned unsatisfied in suit by injured party against insured).”
Cent. Nat'l Ins. Co., of Omaha v. Ins. Co. of North Am., 522 N.W.2d 39 (Iowa 1994). “Second, CNI contends that no matter how the policy is characterized, CNI had an absolute right to proceed against INA under our direct action statute, Iowa Code section 516.1 (1985). A. Fidelity bond or liability policy.”
Yegge v. Integrity Mut. Ins., 534 N.W.2d 100 (Iowa 1995). “Iowa Code § 516.1 states: Inurement of policy.”
Mark Peak v. Ellis Adams & Rachel Adams, 799 N.W.2d 535 (Iowa 2011). “See Iowa Code § 516.1 (allowing direct action against liability insurer only after obtaining a judgment against the insured that remains unsatisfied); see also O’Kelley v.”
Neely v. Am. Fam. Mut. Ins., 930 F. Supp. 360 (N.D. Iowa 1996). “After obtaining a default judgment against the Church, which they were unable to satisfy, the Neelys brought this diversity action against American Family pursuant to Iowa Code § 516.1 to recover the unsatisfied judgment in the underlying lawsuit.”
Beeck v. Kapalis, 302 N.W.2d 90 (Iowa 1981). “Beecks also claimed that all defendants were liable for negligently misrepresenting that Aquaslide manufactured the slide.”
Long v. McAllister, 319 N.W.2d 256 (Iowa 1982). “A third party is given standing to bring an excess judgment suit by the direct action statute, section 516.1, The Code. See Trask v. Iowa Kemper Mutual Insurance Co.”
Dolan v. State Farm Fire & Cas. Co., 573 N.W.2d 254 (Iowa 1998). “When the judgment for damages was not satisfied, Dolan brought a lawsuit against the perpetrator’s insurer under Iowa Code section 516.1 (1993), our direct action statute.”
Ferris v. Employers Mut. Cas. Co., 122 N.W.2d 263 (Iowa 1963). “The plaintiff claims the right of action against the insurer under section 516.1 of the Code, which we quote: “516.”
Iowa Mut. Ins. Co. v. McCarthy, 572 N.W.2d 537 (Iowa 1997). “See Iowa Code § 516.1 (1993). Consequently, the estate has an interest in McCarthy’s insurance coverage.”
Barry v. Milbank Mut. Ins. Co., 188 N.W.2d 326 (Iowa 1971). “Court-tried law action grounded on § 516.1, Code, 1971, brought by judgment creditor of insureds against liability insurance carrier.”
Stucker v. Cnty. of Muscatine, 87 N.W.2d 452 (Iowa 1958). “The Hartford Company also filed special appearances in each ease, and as its basis claimed it was a privy of the eounty defendants and that the jurisdictional question previously decided was res judicata, and for the further reason that the plaintiff could not, due to the bar…”
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