Iowa Code

Iowa Code § 598.21D (2026)

Relocation of parent as grounds to modify order of child custody

✓ current as of July 2026
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If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of the minor child to a location which is one hundred fifty miles or more from the residence of the minor child at the time that custody was awarded, the court may consider the relocation a substantial change in circumstances. If the court determines that the relocation is a substantial change in circumstances, the court shall modify the custody order to, at a minimum, preserve, as nearly as possible, the existing relationship between the minor child and the nonrelocating parent. If modified, the order may include a provision for extended visitation during summer vacations and school breaks and scheduled telephone contact between the nonrelocating parent and the minor child. The modification may include a provision assigning the responsibility for transportation of the minor child for\n\nTue Dec 09 22:00:11 2025 Iowa Code 2026, Chapter 598 (41, 1) §598.21D, DISSOLUTION OF MARRIAGE AND DOMESTIC RELATIONS 18\n\nvisitation purposes to either or both parents. If the court makes a finding of past interference by the parent awarded joint legal custody and physical care or sole legal custody with the minor child’s access to the other parent, the court may order the posting of a cash bond to assure future compliance with the visitation provisions of the decree. The supreme court shall prescribe guidelines for the forfeiting of the bond and restoration of the bond following forfeiting of the bond. 2005 Acts, ch 69, §42 Referred to in §598.20

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Notes of Decisions
Cited in 18 cases (4 in the last 5 years), 2014–2025 · leading case: In Re the Marriage of Tracy Lynn Hoffman & Ernst Franklin Hoffman, Upon the Petition of Tracy Lynn Hoffman, 867 N.W.2d 26 (Iowa 2015).
In Re the Marriage of Tracy Lynn Hoffman & Ernst Franklin Hoffman, Upon the Petition of Tracy Lynn Hoffman, 867 N.W.2d 26 (Iowa 2015). · cites it 4× “In 2005, the legislature enacted section 598.21D, stating: If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of the minor child to a location which is one hundred fifty miles or more from the residence of the minor child…”
In re the Marriage of Greenspon (Iowa Ct. App. 2020). · cites it 8× “Because the modification order satisfied Iowa Code section 598.21D (2019) and served the children’s best interests, we affirm.”
In re the Marriage of Galleger (Iowa Ct. App. 2020). · cites it 6× “1 Iowa Code section 598.21D provides: If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of the minor child to a location which is one hundred fifty miles or more from the residence of the minor child at the time that…”
In re the Marriage of Gunson (Iowa Ct. App. 2025). · cites it 6× “Iowa Code section 598.21D (2024) gives the district court discretion to decide whether a move exceeding 150 miles qualifies as a substantial change in circumstances: 5 If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of…”
Upon the Petition of Brett Allan Morris, & Concerning Sarah Opoien (Iowa Ct. App. 2016). · cites it 4× “Iowa Code section 598.21D provides the court may consider a relocation a substantial change in circumstances if the child is relocated 150 miles or further.”
In Re the Marriage of Christopher Lawrence Slayman & Cassandra Lynn Slayman Upon the Petition of Christopher Lawrence Slayman, & Concerning Cassandra Lynn Slayman, N/K/A Cassandra Lynn Orsi (Iowa Ct. App. 2017). · cites it 4× “He cites Iowa Code section 598.21D (2015), which states that the court may consider a relocation of one-hundred-and-fifty miles or more from the children’s residence at the time that custody was awarded a substantial change in circumstance.”
In re the Marriage of Archer (Iowa Ct. App. 2018). · cites it 4× “Section 598.21D provides: If a parent awarded joint legal custody and physical care .”
In re the Marriage of Lydolph (Iowa Ct. App. 2021). · cites it 4× “He relies on Iowa Code section 598.21D (2020), which gives the district court discretion to decide whether a parent’s relocation of “one hundred fifty miles or more” constitutes a substantial change in circumstances.”
In Re the Marriage of Tracy Lynn Hoffman & Ernst Franklin Hoffman Upon the Petition of Tracy Lynn Hoffman, & Concerning Ernst Franklin Hoffman (Iowa Ct. App. 2014). · cites it 4× “Iowa Code section 598.21D now provides: If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of the minor child to a location which is one hundred fifty miles or more from the residence of the minor child at the time that…”
In Re the Marriage of Jared Allen & Victoria Allen Upon the Petition of Jared Allen, & Concerning Victoria Allen, N/K/A Victoria Cooling (Iowa Ct. App. 2016). · cites it 2× “While the move was not so far that it would qualify for the presumed change of circumstances provided in Iowa Code section 598.21D (providing that a relocation of 150 miles or more may constitute a substantial change in circumstances warranting a modification of a custody…”
In Re the Marriage of Paul A. Stephens & Nichole R. Stephens Upon the Petition of Paul A. Stephens, & Concerning Nichole R. Stephens (Iowa Ct. App. 2014). · cites it 2× “21D (2013) provides: If a parent awarded joint legal custody and physical care or sole legal custody is relocating the residence of the minor child to a location which is one hundred fifty miles or more from the residence of the minor child at the time that custody was awarded,…”
In Re the Marriage of Brian Joseph Hart & Danielle Marie Hart Upon the Petition of Brian Joseph Hart, & Concerning Danielle Marie Hart (Iowa Ct. App. 2014). · cites it 2× “Iowa Code section 598.21D provides in part: If the court determines that the relocation is a substantial change in circumstances, the court shall modify the custody order to, at a minimum, preserve, as nearly as possible, the existing relationship between the minor child and the…”
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