Iowa Code

Iowa Code § 622.33 (2026)

Exception

✓ current as of July 2026
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The provisions of section 622.32, subsection 3, do not apply where the purchase money, or any portion thereof, has been received by the vendor, or when the vendee, with the actual or implied consent of the vendor, has taken and held possession of the premises under and by virtue of the contract, or when there is any other circumstance which, by the law heretofore in force, would have taken the case out of the statute of frauds. [C51, §2411; R60, §4008; C73, §3665; C97, §4626; C24, 27, 31, 35, 39, §11286; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §622.33] Referred to in §622.34

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Notes of Decisions
Cited in 31 cases (2 in the last 5 years), 1947–2025 · leading case: Kolkman v. Roth, 656 N.W.2d 148 (Iowa 2003).
Kolkman v. Roth, 656 N.W.2d 148 (Iowa 2003). · cites it 20× “Iowa Code § 622.33 . This section removes such oral agreements from the domain of the statute under two circumstances.”
Recker v. Gustafson, 279 N.W.2d 744 (Iowa 1979). · cites it 17× “§ 622.33. Cf. Miller v. Lawlor, 245 Iowa 1144 , 66 N.”
Pollmann v. Belle Plaine Livestock Auction, Inc., 567 N.W.2d 405 (Iowa 1997). · cites it 8× “See Iowa Code § 622.33 . Section 622.33 is limited, however, to real estate contracts.”
Miller v. Lawlor, 66 N.W.2d 267 (Iowa 1954). · cites it 8× “Those for the creation or transfer of any interest in lands * * Section 622.33: “Exception. The provisions of subsection 3 of section 622.”
Knight v. Anderson, 292 N.W.2d 411 (Iowa 1980). · cites it 8× “In this regard, the court noted that since the alleged contract was oral, evidence as to the portion of it involving real estate could be used to prove the contract in that particular only if an exception to the statute of frauds applied.”
Hawkeye Land Co. v. Iowa Power & Light Co., 497 N.W.2d 480 (Iowa Ct. App. 1993). · cites it 6× “32 do not apply where the purchase money, or any portion thereof, has been received by the vendor, or when the vendee, with the actual or implied consent of the vendor, has taken and held possession of the premises under and by virtue of the contract, or when there is any other…”
Williams v. Chapman, 46 N.W.2d 56 (Iowa 1951). · cites it 8× “The able and experienced judge to whom the case was submitted found that defendants had established the allegations of their cross-petition with evidence of the quantity and quality required by the decisions of this court, and by section 622.33, Codes of 1946, 1950, and I.”
Garland v. Branstad, 648 N.W.2d 65 (Iowa 2002). · cites it 2× “2d 405, 407 (Iowa 1997); see Iowa Code § 622.33 (limiting statutory exception to subsection (3) of section 622.”
Warder & Lee Elevator, Inc. v. Britten, 274 N.W.2d 339 (Iowa 1979). · cites it 2× “The catch-all exception in § 622.33, "or when there is any other circumstance which, by the law heretofore in force, would have taken the case out of the statute of frauds," ceased to be applicable to sales of goods.”
Snater v. Walters, 98 N.W.2d 302 (Iowa 1959). · cites it 4× “32, subsection 3, Code of Iowa, 1958, and if evidence thereof is to be competent the plaintiff must bring himself within the exceptions, section 622.33. The agreement alleged is a lease for a term exceeding one year.”
Davis v. Roberts, 563 N.W.2d 16 (Iowa Ct. App. 1997). · cites it 4× “Iowa Code § 622.33 . The words “purchase money” mean consideration received in whatever form it may exist.”
Olson v. Nextel Partners, Inc., 317 F. Supp. 2d 972 (S.D. Iowa 2004). · cites it 5× “Plaintiff contends that the Court should find that the doctrine of partial performance exception to the statute of frauds as stated in Iowa Code § 622.33 should apply to the present case.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.