Iowa Code

Iowa Code § 517.5 (2026)

Inspection not basis for civil liability

✓ current as of July 2026
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No inspection of any place of employment made by insurance company inspectors or other inspectors inspecting for group self-insurance purposes shall be the basis for the imposition of civil liability upon the inspector or upon the insurance company employing the inspector or upon any group organized for self-insurance purposes which employs an inspector and is regulated by the insurance departments; but this provision refers only to liability arising out of the making of an inspection and shall not be construed to deny or limit the liability of any employer to the employer’s employees or the liability of any insurance carrier on its insurance policy. [C79, 81, §517.5]

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Notes of Decisions
Cited in 8 cases (3 in the last 5 years), 1981–2022 · leading case: Dillon Clark, Agnes Dusabe, Musa Ezeirig, Zarpka Green, Abraham Tarpeh, & Dusty Nyonee v. Ins. Co. State of Pennsylvania, 927 N.W.2d 180 (Iowa 2019).
Dillon Clark, Agnes Dusabe, Musa Ezeirig, Zarpka Green, Abraham Tarpeh, & Dusty Nyonee v. Ins. Co. State of Pennsylvania, 927 N.W.2d 180 (Iowa 2019). · cites it 38× “1168, § 1 (codified as amended at Iowa Code § 517.5 (2017)). Citing Fabricius , 254 Iowa at 1328 , 121 N.”
Royal Indem. Co. v. Factory Mut. Ins. Co., 786 N.W.2d 839 (Iowa 2010). · cites it 4× “FM also asserts the claim is barred under Iowa Code section 517.5 (2001). Royal cross-appeals the district court’s reduction of the jury’s $39.”
Slater v. Farmland Mut. Ins. Co., 334 N.W.2d 728 (Iowa 1983). · cites it 22× “Farmland had moved for the summary judgment based on Iowa Code section 517.5 (1979), which provides immunity for insurance companies which perform safety inspections of any place of employment.”
Thompson v. Bohlken, 312 N.W.2d 501 (Iowa 1981). · cites it 2× “We conclude that claims against insurance carriers were not considered by the legislature to be inimical to the purposes of worker's compensation or public policy at the time of Thompson's accident. See 2A Larson, supra § 72.”
Gordon Berg Garrison v. New Fashion Pork LLP & BWT Holdings LLP (Iowa 2022). · cites it 4× “And most notably, we recently applied rational basis review to reject an inalienable rights clause challenge to the statutory immunity for negligent inspections by workers’ compensation insurers in Iowa Code section 517.5. Clark, 927 N.W.2d at 190– 91.”
Gordon Berg Garrison v. New Fashion Pork LLP & BWT Holdings LLP (Iowa 2022). · cites it 4× “And most notably, we recently applied rational basis review to reject an inalienable rights clause challenge to the statutory immunity for negligent inspections by workers’ compensation insurers in Iowa Code section 517.5. Clark, 927 N.W.2d at 190– 91.”
Gordon Berg Garrison v. New Fashion Pork LLP & BWT Holdings LLP (Iowa 2022). · cites it 4× “And most notably, we recently applied rational basis review to reject an inalienable rights clause challenge to the statutory immunity for negligent inspections by workers’ compensation insurers in Iowa Code section 517.5. Clark, 927 N.W.2d at 190– 91.”
Royal Indem. Co., As Successor In Interest To Globe Indem. Co., A Member Of Royal & Sunalliance Usa, Inc. & Fed. Ins. Co., A Member Of The Chubb Grp. Of Ins. Companies, As Good Faith Subrogees Of Deere & Co., A Delaware Corp. Vs. Factory Mut. Ins. Co. A/k/a Fm Global A/k/a Factory Mut. Eng'g, A Rhode Island Ltd. Liab. Co. v. Factory Mut. Ins. Co. A/k/a Fm Global A/k/a Factory Mut. Eng'g, A Rhode Island Ltd. Liab. Co.. (Iowa 2010). · cites it 6× “Defendant contends there was insufficient evidence that it breached any contract with the plaintiffs’ insured, and, alternatively, that the damages were not within the contemplation of the parties, and the plaintiffs’ claim is barred under Iowa Code section 517.5 (2001). The…”
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