Iowa Code

Iowa Code § 614.24 (2026)

Reversion or use restrictions on land — preservation

✓ current as of July 2026

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1. No action based upon any claim arising or existing by reason of the provisions of any deed or conveyance or contract or will reserving or providing for any reversion, reverted interests or use restrictions in and to the land therein described shall be maintained either at law or in equity in any court to recover real estate in this state or to recover or establish any interest therein or claim thereto, legal or equitable, against the holder of the record title to such real estate in possession after twenty-one years from the recording of such deed of conveyance or contract or after twenty-one years from the admission of said will to probate unless the claimant shall, personally, or by the claimant’s attorney or agent, or if the claimant is a minor or under legal disability, by the claimant’s guardian, trustee, or either parent or next friend, file a verified claim with the recorder of the county wherein said real estate is located within said twenty-one year period. In the event said deed was recorded or will was\n\nTue Dec 09 21:59:36 2025 Iowa Code 2026, Chapter 614 (37, 0) 13 LIMITATIONS OF ACTIONS, §614.26\n\nadmitted to probate more than twenty years prior to July 4, 1965, then said claim may be filed on or before one year after July 4, 1965. Such claims shall set forth the nature thereof, also the time and manner in which such interest was acquired. For the purposes of this section, the claimant shall be any person or persons claiming any interest in and to said land or in and to such reversion, reverter interest or use restriction, whether the same is a present interest or an interest which would come into existence if the happening or contingency provided in said deed or will were to happen at once. Said claimant further shall include any member of a class of persons entitled to or claiming such rights or interests. 2. The provisions of this section requiring the filing of a verified claim shall not apply to the reversion of railroad property if the reversion is caused by the property being abandoned for railway purposes and the abandonment occurs after July 1, 1980. The holder of such a reversionary interest may bring an action based upon the interest regardless of whether a verified claim has been filed under this section at any time after July 4, 1965. 3. This section shall not impair the validity of an environmental covenant established pursuant to chapter 455I. 4. This section shall not extinguish, limit, or impair the validity of a document or instrument specified in section 499A.23 or 499B.21, or any property interests created by such document or instrument. 5. As used in this section, “use restrictions” means a limitation or prohibition on the rights of a landowner to make use of the landowner’s real estate, including but not limited to limitations or prohibitions on commercial uses, rental use, parking and storage of recreational vehicles and their attachments, ownership of pets, outdoor domestic uses, construction and use of accessory structures, building dimensions and colors, building construction materials, and landscaping. As used in this section, “use restrictions” does not include any of the following: a. An easement granting a person an affirmative right to use land in the possession of another person including but not limited to an easement for pedestrian or vehicular access, reasonable ingress and egress, solar access, utilities, supporting utilities, parking areas, bicycle paths, and water flow. b. An agreement between two or more parcel owners providing for the sharing of costs and other obligations for real estate taxes, insurance premiums, and for maintenance, repair, improvements, services, or other costs related to two or more parcels of real estate regardless of whether the parties to the agreement are owners of individual lots or incorporated or unincorporated lots or have ownership interests in common areas in a horizontal property regime or residential housing development. c. An agreement between two or more parcel owners for the joint use and maintenance of driveways, party walls, landscaping, fences, wells, roads, common areas, waterways, or bodies of water. [C66, 71, 73, 75, 77, 79, 81, §614.24] 2005 Acts, ch 102, §18; 2007 Acts, ch 22, §103; 2014 Acts, ch 1067, §1; 2014 Acts, ch 1095, §5, 6 Referred to in §229.27, 327G.77, 455I.9, 457A.2, 499A.23, 499B.21, 614.26, 614.27, 614.28

Notes of Decisions

Cited in 35 cases (6 in the last 5 years), 1970–2024 · leading case: Amana Soc'y v. Colony Inn, Inc., 315 N.W.2d 101 (Iowa 1982).

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Amana Soc'y v. Colony Inn, Inc., 315 N.W.2d 101 (Iowa 1982). · cites it 77× “The defendants, all stockholders in the Amana Society and businessmen in Amana, challenged the board’s right to assert control of their land on several grounds: They contended Iowa’s “stale use” statute, § 614.24, The Code 1975, barred enforcement of the board’s business…”

Presbytery of Se. Iowa v. Harris, 226 N.W.2d 232 (Iowa 1975). · cites it 73× “2d 181 (1965) the New York Court of Appeals held a statute similar to Iowa Code §§ 614.24 to 614.28 unconstitutional when applied to a possibility of reverter.”

Fjords North, Inc. v. Hahn, 710 N.W.2d 731 (Iowa 2006). · cites it 23× “See Iowa Code § 614.24 (2001) (“No action based on any claim arising or existing by reason of the provisions of any .”

Lowers v. United States, 663 N.W.2d 408 (Iowa 2003). · cites it 19× “The four certified questions are as follows: *410 (1) Is the deed cited above [in the federal court’s certified question order] a defeasible fee or an easement? (2) Did the Stale Uses and Reversions Act (SURA), Iowa Code § 614.24 , operate to vest fee simple absolute ownership…”

Compiano v. Kuntz, 226 N.W.2d 245 (Iowa 1975). · cites it 31× “In this appeal we must decide whether § 614.24 of the Code applies to the facts.”

McKinley v. Waterloo R.R., 368 N.W.2d 131 (Iowa 1985). · cites it 15× “24 provides: No action based upon any claim arising or existing by reason of the provisions of any deed or conveyance or contract or will reserving or providing for any reversion, reverted interests or use restrictions in and to the land therein described shall be maintained…”

Chicago & North W. Ry. Co. v. City of Osage, 176 N.W.2d 788 (Iowa 1970). · cites it 12× “Plaintiff further alleged the deeds by which its predecessor in interest took title to the real estate described contained no reverter clauses and specifically alleged in paragraph 5 that if there had been any right of reversion to defendant provided for it would now be barred…”

Rasmussen v. Yentes, 522 N.W.2d 844 (Iowa Ct. App. 1994). · cites it 10× “It also claimed the reversion issue was not timely under Iowa Code section 614.24 (1985). The City asked for dismissal of the action, or in the alternative, for a full evidentiary hearing.”

Johnson v. Burlington N., Inc., 294 N.W.2d 63 (Iowa Ct. App. 1980). · cites it 8× “77, The Code 1977, attached a reversionary interest in the property, and 3) in finding section 614.24, The Code 1977, bars this action.”

Compiano v. Jones, 269 N.W.2d 459 (Iowa 1978). · cites it 11× “The question in this case is whether a verified statement of claim filed by defendants in the office of the Polk County recorder is effective under § 614.24, The Code, to extend certain use restrictions on Polk County real estate.”

Hawk v. Rice, 325 N.W.2d 97 (Iowa 1982). · cites it 4× “Upon Rice’s appeal the court of appeals reversed, holding that the deed conveyed a determinable fee that did not revert because the possibility of reverter was not preserved in accordance with the stale uses and reversions statute, Iowa Code section 614.24 (1975). We vacate the…”

Burgess v. United States, 109 Fed. Cl. 223 (Fed. Cl. 2013). · cites it 5× “Takings case; Cross-motions for partial summary judgment; Rails-to-Trails Act; Determination of claimant’s property interests; Preseault\ Iowa law construed; Easements for railroad purposes; Railroad relocation — fee simple deeds; Deeds executed under threat of condemnation;…”

Show all 35 citing cases →

— Iowa Code § 614.24(1) — 3 cases

Steven Schueller v. Allison Gillies & Stone Hill Cmty. Ass'n (Iowa Ct. App. 2021).

In the Matter of the Est. of Vera E. Cawiezell (Iowa Ct. App. 2020).

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).

— Iowa Code § 614.24(2) — 1 case

Amana Soc'y v. Colony Inn, Inc., 315 N.W.2d 101 (Iowa 1982). “The defendants, all stockholders in the Amana Society and businessmen in Amana, challenged the board’s right to assert control of their land on several grounds: They contended Iowa’s “stale use” statute, § 614.24, The Code 1975, barred enforcement of the board’s business…”

— Iowa Code § 614.24(5) — 2 cases

WOHLOA, Inc v. The Lake Cabin, LLC (Iowa Ct. App. 2024).

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).

— Iowa Code § 614.24(5)(a) — 1 case

Shri Lambodara, Inc. v. Parco, Ltd. (Iowa Ct. App. 2023).

— Iowa Code § 614.24(5)(c) — 1 case

Gene L. Franklin & Connie Johnson, Executors of the Fae Black Est. Gene L. Franklin, Connie Johnson, Curtis L. Franklin, & Gregory S. Franklin, plaintiffs-appellees/cross-appellants v. Michael Johnston, Elizabeth Johnston, Steve Johnston, Kasondra Johnston, James Yeager, & Judith Yeager, defendants-appellants/cross-appellees. (Iowa Ct. App. 2017).

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