Iowa Code » Chapter 633 — PROBATE CODE
Iowa Code

Iowa Code § 633.37 (2026)

Orders without notice

✓ current as of July 2026
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All orders entered without notice or appearance are reviewable by the court at any time prior to the entry of the order approving the final report. [C66, 71, 73, 75, 77, 79, 81, §633.37]

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Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1968–2022 · leading case: Ritter v. Dagel, 156 N.W.2d 318 (Iowa 1968).
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Ritter v. Dagel, 156 N.W.2d 318 (Iowa 1968). · cites it 24× “Section 633.37, quoted in Division II, supra, does not afford plaintiff an avoidance *324 of the bar of the statute of limitations.”
Patten Ex Rel. Patten v. Patrick, 276 N.W.2d 390 (Iowa 1979). · cites it 8× “Larry's right to a subsequent evidentiary hearing on the guardianship appointment was statutorily insured by section 633.37 which provides: Orders without notice.”
In Re Guardianship of Jordan, 616 N.W.2d 553 (Iowa 2000). · cites it 8× “Iowa Code § 633.37 . B. Notice requirements.”
In Re the Est. of Devries, 203 N.W.2d 308 (Iowa 1972). · cites it 6× “The Department relies upon section 633.37 of the Code, which provides that orders in probate entered *310 without notice or appearance are reviewable by the court at any time before approval of the executor’s final report.”
Hutcheson v. Firstar Bank Burlington, N.A., 490 N.W.2d 833 (Iowa 1992). · cites it 2× “Initially, we recognize that the district court could have set aside the attorney fee allowance without notice or a hearing.”
In Re the Guardianship & Conservatorship of Sams, 256 N.W.2d 570 (Iowa 1977). “In her application to terminate the guardianship and conservatorship, Connie alleged the order was entered without notice to her.”
Matter of Est. of Heller, 401 N.W.2d 602 (Iowa Ct. App. 1986). · cites it 2× “Iowa Code § 633.37 (1985). If the children were properly notified the orders authorizing payment are final orders.”
In Re the Guardianship & Conservatorship of Liggett, 327 N.W.2d 779 (Iowa Ct. App. 1982). · cites it 4× “” Iowa Code § 633.37 (1981). In the case at bar, the guardian-conservator’s final report was filed on October 12, 1981.”
In the Matter of the Est. of Robert Scott Darrah (Iowa Ct. App. 2022). · cites it 4× “” 9 aside the order admitting the lost will to probate were brought under section 633.37 because the challenged order was filed without notice or appearance.”
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