Iowa Code » Chapter 611 — ACTIONS
Iowa Code

Iowa Code § 611.21 (2026)

Civil remedy not merged in crime

✓ current as of July 2026
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The right of civil remedy is not merged in a public offense and is not restricted for other violation of law, but may in all cases be enforced independently of and in addition to the punishment of the former. [C51, §2500; R60, §4110; C73, §2526; C97, §3444; C24, 27, 31, 35, 39, §10958; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §611.21] 85 Acts, ch 197, §36 Referred to in §611.22

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Notes of Decisions
Cited in 13 cases, 1966–2020 · leading case: Nicole Lara Shumate v. Drake Univ. A/K/A Drake Univ. Law Sch., 846 N.W.2d 503 (Iowa 2014).
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Nicole Lara Shumate v. Drake Univ. A/K/A Drake Univ. Law Sch., 846 N.W.2d 503 (Iowa 2014). · cites it 29× “The court of appeals cited Iowa Code section 611.21, which prevents the merger of a civil remedy into a criminal offense.”
Vaughn v. Ag Processing, Inc., 459 N.W.2d 627 (Iowa 1990). · cites it 4× “Plaintiff makes the additional claim that he can bring an action for wrongful discharge based on the violation of the criminal statutes under Iowa Code section 611.21 (1985). We have held that section 611.”
Heick v. Bacon, 561 N.W.2d 45 (Iowa 1997). · cites it 4× “Iowa Code section 611.21 provides: The right of civil remedy is not merged in a public offense and is not restricted for other violation of law, but may in all cases *54 be enforced independently of and in addition to the punishment of the former.”
Seeman v. Liberty Mut. Ins. Co., 322 N.W.2d 35 (Iowa 1982). · cites it 2× “This holding, however, was based on section 611.21, The Code, which provides: “The right of civil remedy is not merged in a public offense, but may be enforced independently of and in addition to the punishment of the latter.”
Powell v. Khodari-Intergreen Co., 334 N.W.2d 127 (Iowa 1983). · cites it 2× “1 of the Iowa Code and creates civil liability for Defendant’s actions through the operation of Section 611.21 of the 1977 Code of Iowa. As a result of these allegations, plaintiff seeks to recover both actual and exemplary damages from the defendant Khodari-In-tergreen Co.”
Wright v. Daniels, 164 N.W.2d 180 (Iowa 1969). · cites it 8× “Section 611.21, Code of Iowa. The developments in the law as to measure of damage and the right to recover for loss of consortium are not involved in the problem before us.”
Wardlow v. City of Keokuk, 190 N.W.2d 439 (Iowa 1971). · cites it 2× “" See also sections 611.21 and 611.22. However, the survival statute is not involved in this matter since only allegations of loss of companionship and society and mental anguish suffered by the parents were stricken from the petitions.”
Wendelin v. Russell, 147 N.W.2d 188 (Iowa 1966). · cites it 2× “” Section 611.21: “The right of civil remedy is not merged in a public offense, but may in all cases be enforced independently of and in addition to the punishment of the latter.”
Sanon v. City of Pella, 865 N.W.2d 506 (Iowa 2015). “§ 611.21 (“The right of civil remedy is not merged in a public offense and is not restricted for other violation of law, but may in all cases be enforced independently of and in addition to the punishment of the former.”
Winegard v. Larsen, 260 N.W.2d 816 (Iowa 1977). “2d 421, 423 (Iowa 1977); § 611.21, The Code. As a party to the dissolution action involved here, plaintiff is in the class protected by § 598.”
Davis v. Crook, 261 N.W.2d 500 (Iowa 1978). “2d 421, 423-424 (Iowa 1977), we studied the impact of § 611.21, The Code, and reaffirmed an early interpretation holding civil remedies may in all cases be enforced for injuries sustained by reason of public offenses.”
Darling v. Boecker (N.D. Iowa 2020). · cites it 2× “member of the class for whose special benefit the statute was enacted, (2) legislative intent, either explicit or implicit, to create or deny a remedy, (3) whether a private cause of action is consistent with the underlying purpose of the statute and (4) whether the implication…”
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