Iowa Code » Chapter 633 — PROBATE CODE
Iowa Code

Iowa Code § 633.487 (2026)

Limitation on rights

✓ current as of July 2026
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No person, having been served with notice of the hearing upon the final report and accounting of a personal representative or having waived such notice, shall, after the entry of the final order approving the same and discharging the said personal representative, have any right to contest, in any proceeding, other than by appeal, the correctness or the legality of the inventory, the accounting, distribution, or other acts of the personal representative, or the list of heirs set forth in the final report of the personal representative, provided, however, that nothing contained in this section shall prohibit any action against the personal representative and the personal representative’s surety under the provisions of section 633.186 on account of any fraud committed by the personal representative. [C97, §3422; C24, 27, 31, 35, 39, §12073; C46, 50, 54, 58, 62, §638.36; C66, 71, 73, 75, 77, 79, 81, §633.487]

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Notes of Decisions
Cited in 12 cases (1 in the last 5 years), 1977–2026 · leading case: In the Matter of the Est. of Carroll Irving Sampson, Cheryl Ann Murken & Mary Ann Smith, Coexecutors of the Christine Rosilia Sampson Est., 838 N.W.2d 663 (Iowa 2013).
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In the Matter of the Est. of Carroll Irving Sampson, Cheryl Ann Murken & Mary Ann Smith, Coexecutors of the Christine Rosilia Sampson Est., 838 N.W.2d 663 (Iowa 2013). · cites it 16× “Iowa Code § 633.487 . Next, section 633.488 provides: Reopening settlement.”
In Re Est. of Warrington, 686 N.W.2d 198 (Iowa 2004). · cites it 13× “The remainderpersons contend the district court did not abuse its discretion in refusing to reopen the estate for three reasons: (1) the' court correctly determined Leona waived her right to consume the principal; (2) Leona’s claim is barred by the provisions of Iowa Code…”
Liska v. First Nat'l Bank in Sioux City, 310 N.W.2d 531 (Iowa Ct. App. 1981). · cites it 13× “Plaintiff contends, essentially, that there was a genuine issue of material fact presented on the fraud allegation such that summary judgment should not have been granted and that the trial court incorrectly ruled that the plaintiff’s malpractice action was barred by section…”
Lynch v. Merchants Nat'l Bank of Cedar Rapids, 491 N.W.2d 157 (Iowa 1992). · cites it 10× “The district court found the petitioner’s claim was barred by Iowa Code section 633.487 (1989) and that no proper cause for reopening the estate had been *158 established.”
Elkader Prod. Credit Ass'n v. Eulberg, 251 N.W.2d 234 (Iowa 1977). · cites it 3× “In essence, these appealing defendants now maintain plaintiff’s declaratory judgment action is barred by Section 633.487, The Code 1973. Significantly, however, the defense so interposed is here invoked for the first time.”
In the Matter of the Est. of Ralph Roethler, Kent Lewis & Becky Lewis v. Angela M. Kuehn, Cheryl L. Upton, Jacquelyn F. Betsworth, Daniel W. Roethler, Mary Anne James, James F. Roethler, Donald A. Roethler, Constance L. Duke, Gerald E. Roethler, Kathleen S. Good, John M. Roethler, Daniel Lee Homan, & Frank E. Homan, 801 N.W.2d 833 (Iowa 2011). · cites it 2× “This determination is governed by Iowa Code sections 633.487, 633.488, and 633.489. We review the district court’s preliminary decision as to whether to reopen the estate under section 633.”
Matter of Est. of Witzke, 359 N.W.2d 183 (Iowa 1984). · cites it 2× “This Part consists of sections 633.487, .488 and .489. The court held that sections 633.”
Kleinendorst v. Est. of Kleinendorst (Iowa Ct. App. 2026). · cites it 32× “representative, have any right to contest, in any proceeding, other than by appeal, the correctness or the legality of the inventory, the accounting, distribution, or other acts of the personal representative, or the list of heirs set forth in the final report of the personal…”
Matter of Est. of Prehoda, 309 N.W.2d 516 (Iowa Ct. App. 1981). · cites it 2× “Although plaintiff apparently received notice of the hearing on the final report in her capacity as next friend to her three minor children, we find nothing in the record to establish notice to her in her individual capacity.”
Wykoff v. Witzke, 359 N.W.2d 183 (Iowa 1984). · cites it 2× “This Part consists of sections 633.487, .488 and .489. The court held that sections 633.”
Harold Youngblut v. Leonard Youngblut (Iowa 2020). · cites it 5× “Furthermore, Iowa Code section 633.487 is intended to give preclusive effect to the “distribution” and “the list of heirs” as to all persons with notice upon court approval of the final report.”
In the Matter of the Est. of Helen M. Martin, James Martin & Frank Martin III, Intervenors-Appellants v. Thompson Fam. Holdings, LLC, Claimant-Appellee. (Iowa Ct. App. 2014). · cites it 6× “See Iowa Code §§ 633.487 ,7 .488,8 .489.9 Our supreme court recently summarized the purpose of those three provisions: [S]ection 633.”
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