Iowa Code

Iowa Code § 622.34 (2026)

Contract not denied in the pleadings

✓ current as of July 2026

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The provisions of sections 622.32 and 622.33, relating merely to the proof of contracts, shall not prevent the enforcement of those not denied in the pleadings, except in cases when the contract is sought to be enforced, or damages recovered for the breach thereof, against some person other than the person who made it. [C51, §2412; R60, §4009; C73, §3666; C97, §4627; C24, 27, 31, 35, 39, §11287; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §622.34] 2013 Acts, ch 90, §173

Notes of Decisions

Cited in 7 cases, 1952–2014 · leading case: Warder & Lee Elevator, Inc. v. Britten.

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Warder & Lee Elevator, Inc. v. Britten (Iowa 1979). · cites it 4× “Retained as applicable, however, were the "failure to deny" and "oral evidence of the maker" exceptions contained in § 622.34 and .35 respectively. See § 554.”

Johnson v. Ward (Iowa 1978). · cites it 2× “Even if we were to concede that this contract is within the statute, it is by no means certain plaintiff could not prove his case by calling upon §§ 622.34 or 622.35 to support his cause.”

Kaiser Aluminum & Chem. Sales, Inc. v. Hurst (Iowa 1970). · cites it 2× “section 622.34 provides that certain alleged oral contracts which are unenforceable because of the statute of frauds shall be enforced if they are not denied in the pleadings.”

Fremon v. W. A. Sheaffer Pen Co. (S.D. Iowa 1953). · cites it 4× “, Section 622.34 is made to apply to sales of goods and dioses in action.”

Boylan v. G. L. Morrow Co. (NY 1984). “, Trossbach v Trossbach, 185 Md 47, supra) rejected the rule entirely as ethically untenable and one State anticipated the formulation of the Code by enacting a statutory admission exception (Iowa Code Ann, § 622.34). Dean Stevens concluded his essay with an impassioned plea for…”

Carmichael v. Stone (Iowa 1952). · cites it 4× “*458 The court sustained the objections and like objections to questions propounded another witness concerning defendant's asserted later oral admissions of the contract.”

Douglas v. Stenoien, Lavola Stenoien, Sheryl Stenoien, & Gwendolyn Brown v. Gary Stenoien, Lorri Ann Stenoien A/K/A Lo (Iowa Ct. App. 2014). · cites it 2× “See Iowa Code § 622.34 (providing enforcement of an oral contract shall not be prevented if not denied in pleadings); Johnson v.”

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