Iowa Code

Iowa Code § 614.17A (2026)

Claims to real estate after 1992

✓ current as of July 2026

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1. After July 1, 1992, an action shall not be maintained in a court, either at law or in equity, in order to recover or establish an interest in or claim to real estate if all the following conditions are satisfied: a. The action is based upon a claim arising more than ten years earlier or existing for more than ten years. b. The action is against the holder of the record title to the real estate in possession. c. The holder of the record title to the real estate in possession and the holder’s immediate or remote grantors are shown by the record to have held chain of title to the real estate for more than ten years. 2. a. The claimant within ten years of the date on which the claim arose or first existed must file with the county recorder in the county where the real estate is located a written statement which is duly acknowledged and definitely describes the real estate involved, the nature and extent of the right of interest claimed, and the facts upon which the claim is based. The claimant must file the statement in person or by the claimant’s attorney or agent. If the claimant is a minor or under a legal disability, the statement must be filed by the claimant’s guardian, trustee, or by either parent. b. The filing of a claim shall extend for a further period of ten years the time within which such action may be brought by any person entitled to bring the claim. The person may file extensions for successive claims. 3. Nothing in this section shall be construed to revive any cause of action barred by section 614.17. 91 Acts, ch 183, §37; 2013 Acts, ch 30, §261 Referred to in §614.17, 614.18, 614.19, 614.20

Notes of Decisions

Cited in 12 cases (5 in the last 5 years), 2004–2026 · leading case: Garrett v. Huster, 684 N.W.2d 250 (Iowa 2004).

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Garrett v. Huster, 684 N.W.2d 250 (Iowa 2004). · cites it 17× “He argues the trial court erred in failing to uphold his title to the property on the basis of (1) adverse possession, (2) the bar of Iowa Code section 614.17A (2001), (3) the doctrine of laches, or (4) the doctrine of equitable estoppel.”

In the Matter of the Est. of Lois L. Hord, In the Matter of the Carl R. Hord Trust Anne T. Walsh, Kathryn Trabert, Gary R. Shuck, Donald C. Shuck, Willis E. Shuck, & John Daly v. Larry Waugh, of the Lois Hord Est. & Tr. of the Carl R. Hord Trust, 836 N.W.2d 1 (Iowa 2013). · cites it 22× “In addition, the probate court concluded the ten-year statute of limitations contained in Iowa Code section 614.17A did not bar the action because the remainder beneficiaries’ cause of action did not arise until the termination of the life estate upon Lois’s death.”

In re Est. of Franken (Iowa 2020). · cites it 41× “The executor disallowed the claim and moved for summary judgment on the ground the claim was barred by the limitations period set forth in Iowa Code section 614.17A (2016). The district court granted the estate’s motion.”

Medardo Rivera v. Clear Channel Outdoor, LLC, Lamar Media Corp., TLC Props., Inc., & All Unknown Claiming Any Right Title or Interest in the Prop. (Iowa 2024). · cites it 37× “The court held that the landowner’s action was barred under Iowa Code section 614.17A (2022). The landowner appeals.”

West Lakes Props., L.C. v. Greenspon Prop. Mgmt., Inc. (Iowa Ct. App. 2017). · cites it 32× “, appeals from a district court order on summary judgment finding its right of first refusal unenforceable under Iowa Code section 614.17A (2016). AFFIRMED. Timothy C.”

In re Est. of Franken (Iowa Ct. App. 2019). · cites it 27× “The estate moved for summary judgment, relying in part on Iowa Code section 614.17A (2017). That provision states, “[A]n action shall not be maintained in a court, either at law or in equity, in order to recover or establish an interest in or claim to real estate if .”

129 State, L.L.C., & Patricia J. Brown, as Tr. under the Revocable Living Trust Agreement of Patricia J. Brown v. Howard 209, L.C. (Iowa Ct. App. 2020). · cites it 10× “Howard 209 moved for summary judgment, arguing 129 State’s petition was barred by the ten-year statute of limitations set forth in Iowa Code section 614.17A. See Iowa Code § 614 .17A(1)(a) (2018) (“[A]n action shall not be maintained .”

Julie A. Kraft v. Larry Kraft, Kenneth Kraft, Douglas Kraft, Donald Hirschman, David Hirschman, Myron Hirschman, & Frank Hirschman (Iowa Ct. App. 2021). · cites it 8× “(2) For the purposes of this section, section 614.17A, and sections 614.18 to 614.”

David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). · cites it 6× “Section 614.17A governs such actions filed after July 1, 1992, and precludes “claim[s] arising more than ten years earlier or existing for more than ten years” against a title holder in possession if the title holder has “held chain of title for more than ten years,” id.”

Kleinendorst v. Est. of Kleinendorst (Iowa Ct. App. 2026). · cites it 4× “” Dorothy’s estate moved for summary judgment, joined by Zimmerman and the Andersons.”

State of Iowa v. Larry Gross (Iowa 2019). · cites it 2× “Additionally, section 614.17A(2) limits the lien created by a civil judgment to ten years.”

South Cent. Iowa Landfill Agency v. Elliott J. Corwin, Tassie L. Corwin & All Parties in Possession (Iowa Ct. App. 2024). · cites it 2× “On December 17, 2019, SCILA filed an affidavit of possession under Iowa Code section 614.17A in which SCILA 6 claimed record title ownership of the disputed parcel.”

— Iowa Code § 614.17A(1) — 6 cases

Garrett v. Huster, 684 N.W.2d 250 (Iowa 2004). “He argues the trial court erred in failing to uphold his title to the property on the basis of (1) adverse possession, (2) the bar of Iowa Code section 614.17A (2001), (3) the doctrine of laches, or (4) the doctrine of equitable estoppel.”

In the Matter of the Est. of Lois L. Hord, In the Matter of the Carl R. Hord Trust Anne T. Walsh, Kathryn Trabert, Gary R. Shuck, Donald C. Shuck, Willis E. Shuck, & John Daly v. Larry Waugh, of the Lois Hord Est. & Tr. of the Carl R. Hord Trust, 836 N.W.2d 1 (Iowa 2013). “In addition, the probate court concluded the ten-year statute of limitations contained in Iowa Code section 614.17A did not bar the action because the remainder beneficiaries’ cause of action did not arise until the termination of the life estate upon Lois’s death.”

West Lakes Props., L.C. v. Greenspon Prop. Mgmt., Inc. (Iowa Ct. App. 2017). “, appeals from a district court order on summary judgment finding its right of first refusal unenforceable under Iowa Code section 614.17A (2016). AFFIRMED. Timothy C.”

Medardo Rivera v. Clear Channel Outdoor, LLC, Lamar Media Corp., TLC Props., Inc., & All Unknown Claiming Any Right Title or Interest in the Prop. (Iowa 2024). “The court held that the landowner’s action was barred under Iowa Code section 614.17A (2022). The landowner appeals.”

In re Est. of Franken (Iowa 2020). “The executor disallowed the claim and moved for summary judgment on the ground the claim was barred by the limitations period set forth in Iowa Code section 614.17A (2016). The district court granted the estate’s motion.”

— Iowa Code § 614.17A(1)(a) — 1 case

— Iowa Code § 614.17A(1)(b) — 2 cases

— Iowa Code § 614.17A(1)(c) — 2 cases

Julie A. Kraft v. Larry Kraft, Kenneth Kraft, Douglas Kraft, Donald Hirschman, David Hirschman, Myron Hirschman, & Frank Hirschman (Iowa Ct. App. 2021). “(2) For the purposes of this section, section 614.17A, and sections 614.18 to 614.”

— Iowa Code § 614.17A(2) — 4 cases

In the Matter of the Est. of Lois L. Hord, In the Matter of the Carl R. Hord Trust Anne T. Walsh, Kathryn Trabert, Gary R. Shuck, Donald C. Shuck, Willis E. Shuck, & John Daly v. Larry Waugh, of the Lois Hord Est. & Tr. of the Carl R. Hord Trust, 836 N.W.2d 1 (Iowa 2013). “In addition, the probate court concluded the ten-year statute of limitations contained in Iowa Code section 614.17A did not bar the action because the remainder beneficiaries’ cause of action did not arise until the termination of the life estate upon Lois’s death.”

State of Iowa v. Larry Gross (Iowa 2019). “Additionally, section 614.17A(2) limits the lien created by a civil judgment to ten years.”

David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). “Section 614.17A governs such actions filed after July 1, 1992, and precludes “claim[s] arising more than ten years earlier or existing for more than ten years” against a title holder in possession if the title holder has “held chain of title for more than ten years,” id.”

— Iowa Code § 614.17A(l)(a) — 1 case

In the Matter of the Est. of Lois L. Hord, In the Matter of the Carl R. Hord Trust Anne T. Walsh, Kathryn Trabert, Gary R. Shuck, Donald C. Shuck, Willis E. Shuck, & John Daly v. Larry Waugh, of the Lois Hord Est. & Tr. of the Carl R. Hord Trust, 836 N.W.2d 1 (Iowa 2013). “In addition, the probate court concluded the ten-year statute of limitations contained in Iowa Code section 614.17A did not bar the action because the remainder beneficiaries’ cause of action did not arise until the termination of the life estate upon Lois’s death.”

— Iowa Code § 614.17A(l)(c) — 1 case

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