Iowa Code

Iowa Code § 625.22 (2026)

Attorney fees — costs

✓ current as of July 2026
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1. When judgment is recovered upon a written contract containing an agreement to pay an attorney fee, the court shall allow and tax as a part of the costs a reasonable attorney fee to be determined by the court. 2. In an action against the maker to recover payment on a dishonored check or draft, as defined in section 554.3104, the plaintiff, if successful, may recover, in addition to all other costs or surcharges provided by law, all court costs incurred, including a reasonable attorney fee, or an individual’s cost of processing a small claims recovery such as lost time and transportation costs from the maker of the check or draft. However, lost time and transportation costs of an assignee shall not be awarded under section 631.14 to a person who in the regular course of business takes assignments of instruments or accounts pursuant to chapter 539. Only actual out-of-pocket expenses incurred in obtaining the small claim recovery may be awarded to the assignee. Any additional charges shall be determined by the court. If the defendant is successful in the action and the court determines the action was frivolous, the court may award the defendant reasonable attorney fees. [C97, §3869; C24, 27, 31, 35, 39, §11644; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §625.22] 84 Acts, ch 1217, §2; 87 Acts, ch 137, §2; 2021 Acts, ch 76, §150 Referred to in §554.3513, 625.24, 631.17

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Notes of Decisions
Cited in 96 cases (30 in the last 5 years), 1959–2026 · leading case: Elyse De Stefano v. Apts. Downtown, Inc., 879 N.W.2d 155 (Iowa 2016).
Elyse De Stefano v. Apts. Downtown, Inc., 879 N.W.2d 155 (Iowa 2016). · cites it 22× “See Iowa Code § 625.22 (1979) (authorizing court to tax as costs an attorney fee set as a percentage of the amount recovered).”
Bankers Trust Co. v. Woltz, 326 N.W.2d 274 (Iowa 1982). · cites it 21× “The extent of the right can be governed only by the statute in existence at the time the right vests.”
Van Sloun v. Agans Bros., Inc., 778 N.W.2d 174 (Iowa 2010). · cites it 8× “Iowa Code § 625.22 . Section 625.24 provides that the fees allowed *183 by section 625.”
Schaffer v. Frank Moyer Constr., Inc., 628 N.W.2d 11 (Iowa 2001). · cites it 8× “2d at 70 (remanding for hearing on trial and appellate attorney fees under Iowa Code section 625.22 (1990)); Bankers Trust, 326 N.”
Soults Farms, Inc. v. Charles J. Schafer v. Soults Farms, Inc., 797 N.W.2d 92 (Iowa 2011). · cites it 6× “” Iowa Code § 625.22 . SFI’s only argument against the award of attorney fees is that SFI is not liable for the Schafer loans and the mortgage is invalid or void.”
NevadaCare, Inc. v. Dep't of Human Servs., 783 N.W.2d 459 (Iowa 2010). · cites it 4× “” Iowa Code § 625.22 (1997). A written contract must contain an express provision regarding attorney fees and litigation expenses in order for a court to include attorney fees and litigation expenses in a favorable judgment.”
Home Fed. Sav. & Loan Ass'n of Algona v. Campney, 357 N.W.2d 613 (Iowa 1984). · cites it 8× “105, in which they requested that plaintiff’s attorney fees be determined under Iowa Code section 625.22 (1979) as it read on the date the foreclosure action was begun.”
Peoples Trust & Sav. Bank v. Baird, 346 N.W.2d 1 (Iowa 1984). · cites it 10× “1181 § 1; see Iowa Code § 625.22 (1981). The bank contends that when the legislature changed section 625.”
GreatAmerica Leasing Corp. v. Cool Comfort Air Conditioning & Refrigeration, Inc., 691 N.W.2d 730 (Iowa 2005). · cites it 4× “Iowa Code section 625.22 (2003). A reasonable attorney fee is not limited to the hourly fee charged by lawyers.”
C & J Vantage Leasing Co., Assignor to Frontier Leasing Corp., Assignee v. Thomas Wolfe D/B/A Lake Macbride Golf Course & Thomas Wolfe, Individually, 795 N.W.2d 65 (Iowa 2011). · cites it 2× “See Iowa Code § 625.22 (permitting the court to award reasonable attorney fees when judgment is recovered upon a written contract containing an agreement to pay attorney fees).”
First Midwest Corp. v. Corp. Fin. Assocs., 663 N.W.2d 888 (Iowa 2003). · cites it 4× “In resisting the stay, First Midwest (1) contested the Nebraska court’s finding that fact issues existed, claiming the case in Iowa could be decided by way of summary judgment to avoid the time and expense of trial and, (2) urged that in Iowa (by contrast to Nebraska), First…”
Fed. Land Bank of Omaha v. Woods, 480 N.W.2d 61 (Iowa 1992). · cites it 2× “We reject the Woods’ contention that the award of attorney fees must be governed by the version of section 625.22 in effect when the note was signed (1975), rather than the version in existence at the time of judgment (1990).”
— Iowa Code § 625.22(1) — 2 cases
Archdale Funding, LLC v. Michael Kim (Iowa Ct. App. 2022).
Cnty. Bank v. Shalla (Iowa Ct. App. 2024).
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