Iowa Code » Chapter 614 — LIMITATIONS OF ACTIONS
Iowa Code

Iowa Code § 614.4 (2026)

Fraud — mistake — trespass

✓ current as of July 2026
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In actions for relief on the ground of fraud or mistake, and those for trespass to property, the cause of action shall not be deemed to have accrued until the fraud, mistake, or trespass complained of shall have been discovered by the party aggrieved. [C51, §1660; R60, §2741; C73, §2530; C97, §3448; C24, 27, 31, 35, 39, §11010; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §614.4] Referred to in §614.6

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Notes of Decisions
Cited in 32 cases, 1949–2020 · leading case: Nixon v. State, 704 N.W.2d 643 (Iowa 2005).
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Nixon v. State, 704 N.W.2d 643 (Iowa 2005). · cites it 20× “Prior to 1965, this court had never applied the discovery rule outside the legislatively authorized area of equitable fraud, mistake, and trespass, see Iowa Code § 614.4 (1962), and the statutory discovery rule had been strictly limited to the types of claims expressly listed in…”
Rathje v. Mercy Hosp., 745 N.W.2d 443 (Iowa 2008). · cites it 4× “The plaintiffs did not file a cross-motion for summary judgment, Thus, we are not presented with the question whether the Rathjes filed their petition within the two-year statute of limitations period as a matter of law.”
Bob McKiness Excavating & Grading, Inc. v. Morton Bldgs., Inc., 507 N.W.2d 405 (Iowa 1993). · cites it 6× “See Iowa Code § 614.4 . The party asserting an exception to a limitations period has the burden of proving the exception.”
Haupt v. Miller, 514 N.W.2d 905 (Iowa 1994). · cites it 4× “Ruigh filed a second motion to dismiss on the ground that Haupt's claim for fraudulent misrepresentation was time barred under Iowa Code section 614.4. The district court denied this motion.”
Rock v. Warhank, 757 N.W.2d 670 (Iowa 2008). · cites it 4× “[3] In interpreting Iowa Code section 614.4 (2008), the statute of limitations for fraud, mistake, and trespass, we have held the term "knowledge" includes not only actual knowledge but also knowledge that has been imputed from the date of inquiry regardless of whether there is…”
Koppes v. Pearson, 384 N.W.2d 381 (Iowa 1986). · cites it 4× “1(4) provides a five-year limitation for "relief on the ground of fraud," and section 614.4 provides that a fraud action is not deemed to have accrued until the fraud has been discovered by the aggrieved party.”
Grove v. Principal Mut. Life Ins., 14 F. Supp. 2d 1101 (S.D. Iowa 1998). · cites it 5× “Plaintiffs argue that they are not *1108 barred from bringing this action because the applicable statute of limitations was tolled pursuant to Iowa Code § 614.4 . Section 614.1 of the Iowa Code provides, in pertinent part: Actions may be brought within the times herein limited .”
Pride v. Peterson, 173 N.W.2d 549 (Iowa 1970). · cites it 6× “Defendant urges in support of the trial court’s ruling that assuming plaintiff’s petition states a cause of action based upon fraud it shows on its face it is a claim for money damages only and therefore her action is not protected by Code section 614.4 but only by sections…”
Regal Ins. Co. v. Summit Guar. Corp., 324 N.W.2d 697 (Iowa 1982). · cites it 3× “4 which provides: In actions for relief on the ground of fraud or mistake, and those for trespass to property, the cause of action shall not be deemed to have accrued until the fraud, mistake, or trespass complained of shall have been discovered by the party aggrieved.”
Midwest Mgmt. Corp. v. Stephens, 353 N.W.2d 76 (Iowa 1984). · cites it 2× “Iowa Code § 614.4 (1983). Prior to that time he had relied on other defenses (statute of frauds and various alleged securities law violations).”
Chrischilles v. Griswold, 150 N.W.2d 94 (Iowa 1967). · cites it 2× “Section 614.4. It has been said “simply and clearly stated *462 the discovery rule is: The limitation statute or statutes in malpractice cases do not start to run until the date of discovery, or the date when, by the exercise of reasonable care, plaintiff should have discovered…”
Ahrendsen v. Iowa Dep't of Human Servs., 613 N.W.2d 674 (Iowa 2000). · cites it 2× “See Iowa Code § 614.4 (in actions for relief on ground of mistake, cause of action shall not be deemed to have accrued until mistake is discovered by aggrieved party).”
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