Iowa Code » Chapter 633 — PROBATE CODE
Iowa Code

Iowa Code § 633.270 (2026)

Contractual or mutual wills

✓ current as of July 2026
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No will shall be construed to be contractual or mutual, unless in such will the testator shall expressly state the intent that such will shall be so construed. [C66, 71, 73, 75, 77, 79, 81, §633.270]

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Notes of Decisions
Cited in 9 cases, 1967–2004 · leading case: In Re Est. of Graham, 690 N.W.2d 66 (Iowa 2004).
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In Re Est. of Graham, 690 N.W.2d 66 (Iowa 2004). · cites it 10× “” Iowa Code § 633.270 . In other words, extrinsic evidence of testator intent is not permitted; the evidence must be found within the four corners of the will itself.”
Morris v. Morris, 383 N.W.2d 527 (Iowa 1986). · cites it 8× “Iowa Code section 633.270 (1985) provides: *530 No will shall be construed to be contractual or mutual, unless in such will the testator shall expressly state the intent that such will shall be so construed.”
Sawyer v. Sawyer, 152 N.W.2d 605 (Iowa 1967). · cites it 2× “” See comment concerning this provision quoted in Floerchinger v.”
Floerchinger v. Williams, 148 N.W.2d 410 (Iowa 1967). · cites it 2× “” Section 633.270 provides: “Contractual or mutual wills.”
Est. of Randall v. McKibben, 191 N.W.2d 693 (Iowa 1971). · cites it 2× “Randall died April 13, 1930, The Code 1970, Section 633.270, is not instantly applicable.”
Matter of Est. of Chapman, 239 N.W.2d 869 (Iowa 1976). “" (§ 633.270, The Code) The preamble already set out satisfies this statutory requirement as to proof, specifically declaring the documents to be the *872 mutual wills of the testators and directing disposition of their property by virtue thereof.”
Matter of Est. of Prehoda, 309 N.W.2d 516 (Iowa Ct. App. 1981). · cites it 2× “Giving this construction to the statutory requirement, it follows that the intent which must be expressly stated in the will in order to comply with section 633.270 is the intent to bind the joint testators to dispose of their property in a certain way.”
In Re Est. of Ryder, 219 N.W.2d 552 (Iowa 1974). “We should mention our present § 633.270, The Code, providing that only wills which expressly state such intention may be construed as mutual is not applicable here because all rights under the challenged instrument would have vested at the death of Fannie Ryder, long before the…”
Lamphier v. Chapman, 239 N.W.2d 869 (Iowa 1976). “” (§ 633.270, The Code) The preamble already set out satisfies this statutory requirement as to proof, specifically declaring the documents to be the *872 mutual wills of the testators and directing disposition of their property by virtue thereof.”
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.