Iowa Code

Iowa Code § 598.41 (2026)

Custody of children

✓ current as of July 2026

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1. a. The court may provide for joint custody of the child by the parties. The court, insofar as is reasonable and in the best interest of the child, shall order the custody award, including liberal visitation rights where appropriate, which will assure the child the opportunity for the maximum continuing physical and emotional contact with both parents after the parents have separated or dissolved the marriage, and which will encourage parents to share the rights and responsibilities of raising the child unless direct physical harm or significant emotional harm to the child, other children, or a parent is likely to result from such contact with one parent. b. Notwithstanding paragraph “a”, if the court finds that a history of domestic abuse exists, a rebuttable presumption against the awarding of joint custody exists. c. The court shall consider the denial by one parent of the child’s opportunity for

Tue Dec 09 22:00:11 2025 Iowa Code 2026, Chapter 598 (41, 1) 27 DISSOLUTION OF MARRIAGE AND DOMESTIC RELATIONS, §598.41\n\nmaximum continuing contact with the other parent, without just cause, a significant factor in determining the proper custody arrangement. Just cause may include a determination by the court pursuant to subsection 3, paragraph “j”, that a history of domestic abuse exists between the parents. d. If a history of domestic abuse exists as determined by a court pursuant to subsection 3, paragraph “j”, and if a parent who is a victim of such domestic abuse relocates or is absent from the home based upon the fear of or actual acts or threats of domestic abuse perpetrated by the other parent, the court shall not consider the relocation or absence of that parent as a factor against that parent in the awarding of custody or visitation. e. Unless otherwise ordered by the court in the custody decree, both parents shall have legal access to information concerning the child, including but not limited to medical, educational and law enforcement records. 2. a. On the application of either parent, the court shall consider granting joint custody in cases where the parents do not agree to joint custody. b. If the court does not grant joint custody under this subsection, the court shall cite clear and convincing evidence, pursuant to the factors in subsection 3, that joint custody is unreasonable and not in the best interest of the child to the extent that the legal custodial relationship between the child and a parent should be severed. c. A finding by the court that a history of domestic abuse exists, as specified in subsection 3, paragraph “j”, which is not rebutted, shall outweigh consideration of any other factor specified in subsection 3 in the determination of the awarding of custody under this subsection. d. Before ruling upon the joint custody petition in these cases, unless the court determines that a history of domestic abuse exists as specified in subsection 3, paragraph “j”, or unless the court determines that direct physical harm or significant emotional harm to the child, other children, or a parent is likely to result, the court may require the parties to participate in custody mediation to determine whether joint custody is in the best interest of the child. The court may require the child’s participation in the mediation insofar as the court determines the child’s participation is advisable. e. The costs of custody mediation shall be paid in full or in part by the parties and taxed as court costs. 3. In considering what custody arrangement under subsection 2 is in the best interest of the minor child, the court shall consider the following factors: a. Whether each parent would be a suitable custodian for the child. b. Whether the psychological and emotional needs and development of the child will suffer due to lack of active contact with and attention from both parents. c. Whether the parents can communicate with each other regarding the child’s needs. d. Whether both parents have actively cared for the child before and since the separation. e. Whether each parent can support the other parent’s relationship with the child. f. Whether the custody arrangement is in accord with the child’s wishes or whether the child has strong opposition, taking into consideration the child’s age and maturity. g. Whether one or both of the parents agree or are opposed to joint custody. h. The geographic proximity of the parents. i. Whether the safety of the child, other children, or the other parent will be jeopardized by the awarding of joint custody or by unsupervised or unrestricted visitation. j. Whether a history of domestic abuse, as defined in section 236.2, exists. In determining whether a history of domestic abuse exists, the court’s consideration shall include but is not limited to commencement of an action pursuant to section 236.3, the issuance of a protective order against the parent or the issuance of a court order or consent agreement pursuant to section 236.5, the issuance of an emergency order pursuant to section 236.6, the holding of a parent in contempt pursuant to section 664A.7, the response of a peace officer to the scene of alleged domestic abuse or the arrest of a parent following response to a report of alleged domestic abuse, or a conviction for domestic abuse assault pursuant to section 708.2A. k. Whether a parent has allowed a person custody or control of, or unsupervised access to a child after knowing the person is required to register or is on the sex offender registry as a sex offender under chapter 692A.

Tue Dec 09 22:00:11 2025 Iowa Code 2026, Chapter 598 (41, 1) §598.41, DISSOLUTION OF MARRIAGE AND DOMESTIC RELATIONS 28\n\n 4. Subsection 3 shall not apply when parents agree to joint custody. 5. a. If joint legal custody is awarded to both parents, the court may award joint physical care to both joint custodial parents upon the request of either parent. Prior to ruling on the request for the award of joint physical care, the court may require the parents to submit, either individually or jointly, a proposed joint physical care parenting plan. A proposed joint physical care parenting plan shall address how the parents will make decisions affecting the child, how the parents will provide a home for the child, how the child’s time will be divided between the parents and how each parent will facilitate the child’s time with the other parent, arrangements in addition to court-ordered child support for the child’s expenses, how the parents will resolve major changes or disagreements affecting the child including changes that arise due to the child’s age and developmental needs, and any other issues the court may require. If the court denies the request for joint physical care, the determination shall be accompanied by specific findings of fact and conclusions of law that the awarding of joint physical care is not in the best interest of the child. b. If joint physical care is not awarded under paragraph “a”, and only one joint custodial parent is awarded physical care, the parent responsible for providing physical care shall support the other parent’s relationship with the child. Physical care awarded to one parent does not affect the other parent’s rights and responsibilities as a joint legal custodian of the child. Rights and responsibilities as joint legal custodian of the child include but are not limited to equal participation in decisions affecting the child’s legal status, medical care, education, extracurricular activities, and religious instruction. 6. If the parties have more than one minor child, and the court awards each party the physical custody of one or more of the children, upon application by either party, and if it is reasonable and in the best interest of the children, the court shall include a provision in the custody order directing the parties to allow visitation between the children in each party’s custody. 7. When a parent awarded legal custody or physical care of a child cannot act as custodian or caretaker because the parent has died or has been judicially adjudged incompetent, the court shall award legal custody including physical care of the child to the surviving parent unless the court finds that such an award is not in the child’s best interest. 8. If an application for modification of a decree or a petition for modification of an order is filed, based upon differences between the parents regarding the custody arrangement established under the decree or order, unless the court determines that a history of domestic abuse exists as specified in subsection 3, paragraph “j”, or unless the court determines that direct physical harm or significant emotional harm to the child, other children, or a parent is likely to result, the court may require the parents to participate in mediation to attempt to resolve the differences between the parents. 9. All orders relating to custody of a child are subject to chapter 598B. [82 Acts, ch 1250, §2] 84 Acts, ch 1088, §2, 3, 4, 5; 85 Acts, ch 67, §57, 58; 86 Acts, ch 1179, §5, 6; 95 Acts, ch 182, §22 – 24; 95 Acts, ch 183, §2; 97 Acts, ch 175, §199, 200; 99 Acts, ch 115, §1; 2004 Acts, ch 1169, §1; 2005 Acts, ch 69, §51 – 53; 2006 Acts, ch 1101, §4; 2012 Acts, ch 1138, §37; 2019 Acts, ch 24, §83 Referred to in §598.7, 598.21C, 598.41A, 598.41B, 600B.40, 600B.41A, 633.560A

Notes of Decisions

Cited in 679 cases (225 in the last 5 years), 1983–2026 · leading case: In Re the Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007).

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In Re the Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007). · cites it 35× “1169, § 1 (now codified at Iowa Code § 598.41 (5) (2005)). Like the 1997 amendment, the 2004 amendment did not contain a new standard to be employed by the courts in considering whether to award joint physical care.”

In Re the Marriage of Angela Marie Harris & Patric David Harris, Upon the Petition of Angela Marie Harris, 877 N.W.2d 434 (Iowa 2016). · cites it 25× “After hearing testimony from Angela, Angela’s witnesses, and Patric, the district court entered a dissolution decree providing in pertinent part as follows: The Court has considered all of the factors set forth in Iowa Code § 598.41 (3). Based on the record made, there is no…”

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 16× “Iowa Code § 598.41 (3)(f) (2013); see Hansen, 733 N.”

In Re the Marriage of Daniels, 568 N.W.2d 51 (Iowa Ct. App. 1997). · cites it 32× “; see Iowa Code § 598.41 . These include the characteristics of the parents, as well as the capacity and desire of each parent to provide for the needs of the children.”

In Re the Marriage of Gensley, 777 N.W.2d 705 (Iowa Ct. App. 2009). · cites it 16× “904(3)(o); Iowa Code § 598.41 . The district court shall make an award that, so long as reasonable and in the best interests of the children, assures the children the “opportunity for the maximum continuing physical and emotional contact with both parents.”

Montgomery v. Wells, 708 N.W.2d 704 (Iowa Ct. App. 2005). · cites it 22× “” Iowa Code § 598.41 (2). We believe an infant child’s name is an incident of the child’s “legal status.”

In Re the Marriage of Ford, 563 N.W.2d 629 (Iowa 1997). · cites it 32× “See Iowa Code § 598.41 (3)(a)-(j) (Supp.1995).”

In Re the Marriage of Miller, 390 N.W.2d 596 (Iowa 1986). · cites it 40× “Iowa Code § 598.41 (1985). [1] The statute emphasizes maximum physical and emotional contact between each parent and child, and gives preference to a joint custody arrangement, when such an arrangement is requested by either parent.”

Mandy Kay Hensch v. Nicholas Allen Mysak, 902 N.W.2d 822 (Iowa Ct. App. 2017). · cites it 6× “” Iowa Code § 598.41 (5)(a). “[T]his passage does not create a presumption in favor of joint physical care.”

In Re Marriage of Hynick, 727 N.W.2d 575 (Iowa 2007). · cites it 10× “See generally Iowa Code § 598.41 (l)(a), (5). Under this arrangement, the parent with primary physical care has the responsibility to maintain a residence for the child and has the sole right to make decisions concerning the child’s routine care.”

In Re the Marriage of Witten, 672 N.W.2d 768 (Iowa 2003). · cites it 10× “” Iowa Code § 598.41 (l)(a). The principles developed under this statute are simply not suited to the resolution of disputes over the control of frozen embryos.”

In Re the Marriage of Kleist, 538 N.W.2d 273 (Iowa 1995). · cites it 18× “See Iowa Code § 598.41 (1995); In re Marriage of Winter, 223 N.”

Show all 679 citing cases →

— Iowa Code § 598.41(1) — 21 cases

In Re the Marriage of Hunt, 476 N.W.2d 99 (Iowa Ct. App. 1991).

In Re the Marriage of Rykhoek, 525 N.W.2d 1 (Iowa Ct. App. 1994).

Lambert v. Everist, 418 N.W.2d 40 (Iowa 1988).

Leaf v. Iowa Methodist Med. Ctr., 460 N.W.2d 892 (Iowa Ct. App. 1990).

Harder v. Anderson, Arnold, Dickey, Jensen, Gullickson & Sanger, L.L.P., 764 N.W.2d 534 (Iowa 2009).

— Iowa Code § 598.41(1)(5) — 1 case

In Re Marriage of Hynick, 727 N.W.2d 575 (Iowa 2007). “See generally Iowa Code § 598.41 (l)(a), (5). Under this arrangement, the parent with primary physical care has the responsibility to maintain a residence for the child and has the sole right to make decisions concerning the child’s routine care.”

— Iowa Code § 598.41(1)(a) — 46 cases

Callender v. Skiles, 623 N.W.2d 852 (Iowa 2001).

Nicholas W. O'brien v. Elizabeth Wygle (Iowa Ct. App. 2014).

John K. Susie v. Marilyn Tejeda (Iowa Ct. App. 2015).

Jarrod Diers v. Robertta Coffman (Iowa Ct. App. 2016).

In Re the Marriage of Tiffany Lane Schultzen & Brad James Schultzen Upon the Petition of Tiffany Lane Schultzen, petitioner-appellee/cross-appellant, & Concerning Brad James Schultzen, respondent-appellant/cross-appellee. (Iowa Ct. App. 2016).

— Iowa Code § 598.41(1)(b) — 20 cases

Javonte Devar Hines Miller v. Ashlea Kay Teter (Iowa 2026).

Javonte Devar Hines Miller v. Ashlea Kay Teter (Iowa Ct. App. 2025).

In re the Marriage of Wieland (Iowa Ct. App. 2022).

Macy Alexander Worth v. Matthew Noel Geinitz (Iowa Ct. App. 2024).

Christopher Fortner v. Stephanie Howe (Iowa Ct. App. 2016).

— Iowa Code § 598.41(1)(c) — 16 cases

In Re the Marriage of Gensley, 777 N.W.2d 705 (Iowa Ct. App. 2009). “904(3)(o); Iowa Code § 598.41 . The district court shall make an award that, so long as reasonable and in the best interests of the children, assures the children the “opportunity for the maximum continuing physical and emotional contact with both parents.”

Jarrod Diers v. Robertta Coffman (Iowa Ct. App. 2016).

Miguel Antonio Hernandez v. Deena Jo Mills (Iowa Ct. App. 2018).

In re the Marriage of DeMoss (Iowa Ct. App. 2020).

In re the Marriage of Frey & Kerres (Iowa Ct. App. 2022).

— Iowa Code § 598.41(1)(d) — 1 case

In re the Marriage of Finley (Iowa Ct. App. 2023).

— Iowa Code § 598.41(1)(e) — 8 cases

In re the Marriage of Serrano (Iowa Ct. App. 2021).

Susan Harder Vs. Anderson, Arnold, Dickey, Jensen, Gullickson & Sanger, L.l.p. & Jane Pini (Iowa 2009).

Sondra Marie Thurman v. Jeremy Shuey (Iowa Ct. App. 2022).

In re Marriage of Makela (Iowa Ct. App. 2022).

C.S., on behalf of H.S., a child v. J.C. (Iowa Ct. App. 2023).

— Iowa Code § 598.41(2) — 14 cases

In Re the Marriage of Miller, 390 N.W.2d 596 (Iowa 1986). “Iowa Code § 598.41 (1985). [1] The statute emphasizes maximum physical and emotional contact between each parent and child, and gives preference to a joint custody arrangement, when such an arrangement is requested by either parent.”

In Re the Marriage of Orte, 389 N.W.2d 373 (Iowa 1986).

In Re the Marriage of Butler, 346 N.W.2d 45 (Iowa Ct. App. 1984).

In Re the Marriage of Stanley, 411 N.W.2d 698 (Iowa Ct. App. 1987).

In Re the Marriage of Behn, 385 N.W.2d 540 (Iowa 1986).

— Iowa Code § 598.41(2)(a) — 3 cases

In re the Marriage of Young (Iowa Ct. App. 2026).

In re the Marriage of Milne (Iowa Ct. App. 2020).

Nicholas R. Rosenow v. Tara D. Link (Iowa Ct. App. 2024).

— Iowa Code § 598.41(2)(b) — 11 cases

In Re the Marriage of Charity Ann Dowell & Troy Daniel Dowell Upon the Petition of Charity Ann Dowell, N/K/A Charity Ann Schneider, & Concerning Troy Daniel Dowell (Iowa Ct. App. 2014).

In Re the Marriage of Stephanie Kay Makela & Wayne L. Makela Upon the Petition of Stephanie Kay Makela, petitioner-appellant/cross-appellee, & Concerning Wayne L. Makela, respondent-appellee/cross-appellant. (Iowa Ct. App. 2017).

In re Marriage of Viers (Iowa Ct. App. 2025).

Auston David Herman v. Holly Noel Morrison (Iowa Ct. App. 2026).

— Iowa Code § 598.41(2)(c) — 6 cases

Javonte Devar Hines Miller v. Ashlea Kay Teter (Iowa 2026).

In re the Marriage of Young (Iowa Ct. App. 2026).

In Re the Marriage of Christopher C. Remrey & Shirlee S. Remrey Upon the Petition of Christopher C. Remrey, & Concerning Shirlee S. Remrey (Iowa Ct. App. 2016).

In Re the Marriage of George Thomas Davis III & Lizeth Marie Barcelo Aviles Upon the Petition of George Thomas Davis III, & Concerning Lizeth Marie Barcelo Aviles (Iowa Ct. App. 2017).

In re the Marriage of Duke (Iowa Ct. App. 2021).

— Iowa Code § 598.41(3) — 346 cases

In Re the Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007). “1169, § 1 (now codified at Iowa Code § 598.41 (5) (2005)). Like the 1997 amendment, the 2004 amendment did not contain a new standard to be employed by the courts in considering whether to award joint physical care.”

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). “Iowa Code § 598.41 (3)(f) (2013); see Hansen, 733 N.”

McKee v. Dicus, 785 N.W.2d 733 (Iowa Ct. App. 2010).

In Re Marriage of Fennelly & Breckenfelder, 737 N.W.2d 97 (Iowa 2007).

— Iowa Code § 598.41(3)(a) — 11 cases

Christopher Fortner v. Stephanie Howe (Iowa Ct. App. 2016).

In re the Marriage of Lang, 919 N.W.2d 636 (Iowa Ct. App. 2018).

State of Iowa v. Alonzo Leroy Jeffrey (Iowa Ct. App. 2020).

Easton Armstrong v. Holly Curtis (Iowa Ct. App. 2021).

— Iowa Code § 598.41(3)(b) — 10 cases

In Re the Marriage of Quirk-Edwards, 509 N.W.2d 476 (Iowa 1993).

In re the Marriage of Cleary (Iowa Ct. App. 2026).

In re the Marriage of Lang, 919 N.W.2d 636 (Iowa Ct. App. 2018).

State of Iowa v. Alonzo Leroy Jeffrey (Iowa Ct. App. 2020).

In re the Marriage of Black (Iowa Ct. App. 2022).

— Iowa Code § 598.41(3)(c) — 11 cases

In Re the Marriage of Butler, 346 N.W.2d 45 (Iowa Ct. App. 1984).

In re the Marriage of Cleary (Iowa Ct. App. 2026).

In re the Marriage of Lang, 919 N.W.2d 636 (Iowa Ct. App. 2018).

Abbigale Jo Courey v. Traelius Anthony Robinson (Iowa Ct. App. 2021).

In re the Marriage of Black (Iowa Ct. App. 2022).

— Iowa Code § 598.41(3)(d) — 9 cases

In Re the Marriage of Ford, 563 N.W.2d 629 (Iowa 1997). “See Iowa Code § 598.41 (3)(a)-(j) (Supp.1995).”

In Re the Marriage of Magaly Duran & Pablo Duran Upon the Petition of Magaly Duran, & Concerning Pablo Duran (Iowa Ct. App. 2016).

Damian Lee Hesseltine v. Drewann Sorensen (Iowa Ct. App. 2019).

State of Iowa v. Alonzo Leroy Jeffrey (Iowa Ct. App. 2020).

In re the Marriage of Black (Iowa Ct. App. 2022).

— Iowa Code § 598.41(3)(e) — 16 cases

In Re the Marriage of Leyda, 355 N.W.2d 862 (Iowa 1984).

In Re the Marriage of Manson, 503 N.W.2d 427 (Iowa Ct. App. 1993).

In re the Marriage of Lewis (Iowa Ct. App. 2019).

In Re the Marriage of Jesse Jacob Leib & Abby Jo Leib Upon the Petition of Jesse Jacob Leib, & Concerning Abby Jo Leib (Iowa Ct. App. 2016).

In Re the Marriage of George Thomas Davis III & Lizeth Marie Barcelo Aviles Upon the Petition of George Thomas Davis III, & Concerning Lizeth Marie Barcelo Aviles (Iowa Ct. App. 2017).

— Iowa Code § 598.41(3)(f) — 9 cases

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). “Iowa Code § 598.41 (3)(f) (2013); see Hansen, 733 N.”

In Re the Marriage of Ellerbroek, 377 N.W.2d 257 (Iowa Ct. App. 1985).

In Re the Marriage of Behn, 416 N.W.2d 100 (Iowa Ct. App. 1987).

In Re the Marriage of Pettit, 493 N.W.2d 865 (Iowa Ct. App. 1992).

In Re the Marriage of Nichole Leigh Severson & Russell Neil Severson II Upon the Petition of Nichole Leigh Severson, & Concerning Russell Neil Severson II (Iowa Ct. App. 2014).

— Iowa Code § 598.41(3)(g) — 3 cases

In Re the Marriage of Kleist, 538 N.W.2d 273 (Iowa 1995). “See Iowa Code § 598.41 (1995); In re Marriage of Winter, 223 N.”

In re the Marriage of Black (Iowa Ct. App. 2022).

In re the Marriage of Cleary (Iowa Ct. App. 2026).

— Iowa Code § 598.41(3)(h) — 4 cases

In re the Marriage of McCusker (Iowa Ct. App. 2022).

Ladawn R. Seward v. Troy P. Hane (Iowa Ct. App. 2016).

In Re the Marriage of Magaly Duran & Pablo Duran Upon the Petition of Magaly Duran, & Concerning Pablo Duran (Iowa Ct. App. 2016).

In Re the Marriage of George Thomas Davis III & Lizeth Marie Barcelo Aviles Upon the Petition of George Thomas Davis III, & Concerning Lizeth Marie Barcelo Aviles (Iowa Ct. App. 2017).

— Iowa Code § 598.41(3)(i) — 4 cases

In Re the Marriage of Brainard, 523 N.W.2d 611 (Iowa Ct. App. 1994).

In Re the Marriage of Daniels, 568 N.W.2d 51 (Iowa Ct. App. 1997). “; see Iowa Code § 598.41 . These include the characteristics of the parents, as well as the capacity and desire of each parent to provide for the needs of the children.”

In re the Marriage of Peck (Iowa Ct. App. 2024).

In re Marriage of Johanns (Iowa Ct. App. 2025).

— Iowa Code § 598.41(3)(j) — 18 cases

Abbigale Jo Courey v. Traelius Anthony Robinson (Iowa Ct. App. 2021).

Robert Joseph Dean v. Lara Winter Bartusek (Iowa Ct. App. 2016).

In Re the Marriage of Christopher C. Remrey & Shirlee S. Remrey Upon the Petition of Christopher C. Remrey, & Concerning Shirlee S. Remrey (Iowa Ct. App. 2016).

In Re the Marriage of Terrence J. Williams & Tammy M. Williams Upon the Petition of Terrence J. Williams, & Concerning Tammy M. Williams (Iowa Ct. App. 2017).

State of Iowa v. Alonzo Leroy Jeffrey (Iowa Ct. App. 2020).

— Iowa Code § 598.41(4) — 9 cases

In Re the Marriage of Bolin, 336 N.W.2d 441 (Iowa 1983).

In Re the Marriage of Zabecki, 389 N.W.2d 396 (Iowa 1986).

In Re the Marriage of Ullerich, 367 N.W.2d 297 (Iowa Ct. App. 1985).

In Re the Marriage of Ertmann, 376 N.W.2d 918 (Iowa Ct. App. 1985).

— Iowa Code § 598.41(5) — 14 cases

In Re Marriage of Ellis, 705 N.W.2d 96 (Iowa Ct. App. 2005).

In Re the Marriage of Angela Marie Harris & Patric David Harris, Upon the Petition of Angela Marie Harris, 877 N.W.2d 434 (Iowa 2016). “After hearing testimony from Angela, Angela’s witnesses, and Patric, the district court entered a dissolution decree providing in pertinent part as follows: The Court has considered all of the factors set forth in Iowa Code § 598.41 (3). Based on the record made, there is no…”

In Re the Marriage of Craig, 462 N.W.2d 692 (Iowa Ct. App. 1990).

In Re the Marriage of Rykhoek, 525 N.W.2d 1 (Iowa Ct. App. 1994).

— Iowa Code § 598.41(5)(6) — 1 case

— Iowa Code § 598.41(5)(a) — 28 cases

In Re Marriage of Fennelly & Breckenfelder, 737 N.W.2d 97 (Iowa 2007).

In Re the Marriage of Berning, 745 N.W.2d 90 (Iowa Ct. App. 2007).

In Re the Marriage of Brittni Heitman & Andrew Heitman Upon the Petition of Brittni Heitman, & Concerning Andrew Heitman (Iowa Ct. App. 2016).

— Iowa Code § 598.41(5)(b) — 11 cases

In Re the Marriage of Cara Lynn Matteson & Taylor Bryce Matteson Upon the Petition of Cara Lynn Matteson, & Concerning Taylor Bryce Matteson (Iowa Ct. App. 2017).

In re the Marriage of Comstock (Iowa Ct. App. 2021).

In re the Marriage of Budden (Iowa Ct. App. 2021).

In re the Marriage of Swalin (Iowa Ct. App. 2025).

— Iowa Code § 598.41(6) — 1 case

Thompson Ex Rel. Thompson v. Collins, 391 N.W.2d 267 (Iowa Ct. App. 1986).

— Iowa Code § 598.41(7) — 2 cases

Ernst v. Grap, 799 N.W.2d 549 (Iowa Ct. App. 2011).

In Re Hough, 590 N.W.2d 556 (Iowa Ct. App. 1999).

— Iowa Code § 598.41(a) — 1 case

In Re the Marriage of Matthew Morris & Allison Morris Upon the Petition of Matthew Morris, & Concerning Allison Morris, N/K/A Allison Walsh (Iowa Ct. App. 2014).

— Iowa Code § 598.41(l)(a) — 1 case

Callender v. Skiles, 623 N.W.2d 852 (Iowa 2001).

— Iowa Code § 598.41(l)(b) — 2 cases

In Re the Marriage of Forbes, 570 N.W.2d 757 (Iowa 1997).

In Re the Marriage of Ford, 563 N.W.2d 629 (Iowa 1997). “See Iowa Code § 598.41 (3)(a)-(j) (Supp.1995).”

— Iowa Code § 598.41(l)(d) — 1 case

In Re the Marriage of Ford, 563 N.W.2d 629 (Iowa 1997). “See Iowa Code § 598.41 (3)(a)-(j) (Supp.1995).”

— Iowa Code § 598.41(l)(e) — 2 cases

Harder v. Anderson, Arnold, Dickey, Jensen, Gullickson & Sanger, L.L.P., 764 N.W.2d 534 (Iowa 2009).

Marc Ruden v. Kyra Peach, 904 N.W.2d 410 (Iowa Ct. App. 2017).

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