Iowa Code
Iowa Code § 613.15 (2026)
Injury or death of spouse or parent — measure of recovery
✓ current as of July 2026
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In any action for damages because of the wrongful or negligent injury or death of a woman, there shall be no disabilities or restrictions, and recovery may be had on account thereof in the same manner as in cases of damage because of the wrongful or negligent injury or death of a man. In addition she, or her administrator for her estate, may recover for physician’s services, nursing and hospital expense, and in the case of both women and men, such person, or the appropriate administrator, may recover the value of services and support as spouse or parent, or both, as the case may be, in such sum as the jury deems proper; provided, however, recovery for these elements of damage may not be had by the spouse and children, as such, of any person who, or whose administrator, is entitled to recover same. [SS15, §3477-a; C24, 27, §10463; C31, 35, §10991-d1; C39, §10991.1; C46, 50, 54, 58, 62, §613.11; C66, 71, 73, 75, 77, 79, 81, §613.15]
\nNotes of Decisions
Cited in 70
cases (4 in the last 5 years), 1966–2026 · leading case: Madison v. Colby, 348 N.W.2d 202 (Iowa 1984).
Madison v. Colby, 348 N.W.2d 202 (Iowa 1984). “15, provides: In any action for damages because of the wrongful or negligent injury or death of a woman, there shall be no disabilities or restrictions, and recovery may be had on account thereof in the same manner as in cases of damage because of the wrongful or negligent…”
Audubon-Exira Ready Mix, Inc. v. Illinois Cent. Gulf R.R., 335 N.W.2d 148 (Iowa 1983). “15 provides: In any action for damages because of the wrongful or negligent injury or death of a woman, there shall be no disabilities or restrictions, and recovery may be had on account thereof in the same manner as in cases of damage because of the wrongful or negligent injury…”
Mary E. Roth & Michael A. Roth, Individually & as Coexecutors of the Est. of Cletus Roth, Anna M. Roth, Individually, & Bradley E. Roth, Individually v. the Evangelical Lutheran Good Samaritan Soc'y D/B/A Good Samaritan Soc'y - George, 886 N.W.2d 601 (Iowa 2016). “Iowa Code § 613.15 . So worded, Iowa Code section 613.”
Schmitt v. Jenkins Truck Lines, Inc., 170 N.W.2d 632 (Iowa 1969). “It does not afford a remedy for loss of service or support of a spouse where none survives. This section provides: "In any action for damages because of the wrongful or negligent injury or death of a woman, there shall be no disabilities or restrictions, and recovery may be had…”
Wardlow v. City of Keokuk, 190 N.W.2d 439 (Iowa 1971). “Section 613.15, The Code, set out infra. The other case mentioned, supra, as among those cited by plaintiffs, Leahy v.”
Hankins Ex Rel. Hankins v. Derby, 211 N.W.2d 581 (Iowa 1973). “In any action for damages because of the wrongful or negligent injury or death of a woman, there shall be no disabilities or restrictions, and recovery may be had on account thereof in the same manner as in cases of damage because of the wrongful or negligent injury or death of…”
Haafke v. Mitchell, 347 N.W.2d 381 (Iowa 1984). “Iowa Code § 613.15 . In Iowa-Des Moines National Bank v.”
Kulish v. West Side Unlimited Corp., 545 N.W.2d 860 (Iowa 1996). “The Kulishes’ brief states ”[i]t is a well-established rule of common law that adult children in Iowa can bring loss of consortium claims for the injury to or death of a parent.”
Kuta v. Newberg, 600 N.W.2d 280 (Iowa 1999). “The plaintiffs claimed that Iowa Rule of Civil Procedure 8 (which allows consortium damages for the death of a minor child but not an adult child) and Iowa Code section 613.15 (which allows suits for loss of consortium of parents, but not for the loss of children) violate equal…”
Horak v. Argosy Gaming Co., 648 N.W.2d 137 (Iowa 2002). “It acknowledges that, to do so, we would have to overrule long-established precedent interpreting Iowa Code section 613.15. See Audubon-Exira, 335 N.”
Hutchinson v. Broadlawns Med. Ctr., 459 N.W.2d 273 (Iowa 1990). “In the cross-appeal, the granddaughter contends that the district court erred in dismissing her claim for damages because (1) Billy Hutchinson was a “parent” for purposes of assessing death damages under Iowa Code section 613.”
Nelson v. Ludovissy, 368 N.W.2d 141 (Iowa 1985). “” Appellants in the present case contend that, to the extent section 613.15 designated the injured parent as the proper party to prosecute the child’s claim for loss of services and support, this is only a statutory “next friend” designation applicable to minor children.”
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