Iowa Code » Chapter 633A — IOWA TRUST CODE
Iowa Code

Iowa Code § 633A.4504 (2026)

Limitation of action against trustee

✓ current as of July 2026
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1. Unless previously barred by adjudication, consent, or other limitation, a claim against a trustee for breach of trust is barred as to a beneficiary who has received an accounting pursuant to section 633A.4213 or other report that adequately discloses the existence of the claim, unless a proceeding to assert the claim is commenced within one year after the receipt of the accounting or report. An accounting or report adequately discloses the existence of a claim if it provides sufficient information so that the beneficiary knows of the claim or reasonably should have inquired into its existence.

2. For the purpose of subsection 1, a beneficiary is deemed to have received an accounting or report in the following instances:

a. In the case of an adult who is reasonably capable of understanding the accounting or report, if it is received by the adult personally.

b. In the case of an adult who is not reasonably capable of understanding the accounting or report, if it is received by the adult’s legal representative, including a guardian ad litem or other person appointed for this purpose.

c. In the case of a minor, if it is received by the minor’s guardian or conservator or, if the minor does not have a guardian or conservator, if it is received by a parent of the minor who does not have a conflict of interest.

3. Any claim for breach of trust against a trustee who has presented an accounting or report to a beneficiary more than one year prior to July 1, 2000, shall be time barred unless some exception stated in this section applies which tolls the statute. Any claim arising under this section within one year of July 1, 2000, shall be time barred after one year unless an exception applies to toll the statute.

4. For the purposes of this section, “report” means a document including but not limited to a letter, delivered by or on behalf of the trustee to a beneficiary of the trust. 99 Acts, ch 125, §76, 109; 2000 Acts, ch 1150, §25 C2001, §633.4504 2005 Acts, ch 38, §54 CS2005, §633A.4504 2012 Acts, ch 1123, §28; 2013 Acts, ch 33, §7, 9 Referred to in §633A.4213, 633A.5108 \n

Notes of Decisions
Cited in 5 cases (1 in the last 5 years), 2007–2024 · leading case: Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust, 925 N.W.2d 620 (Iowa 2019).
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Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust, 925 N.W.2d 620 (Iowa 2019). · cites it 25× “Second, the defendants maintain Konrardy's and Burmeister's claims fail on the merits because the language of the trust "clearly and unambiguously" requires their share of the trust to be valued as of the date of Angerer's death rather than at the time of distribution. We…”
Turner v. Iowa State Bank & Trust Co. of Fairfield, 743 N.W.2d 1 (Iowa 2007). · cites it 16× “The co-trustees relied on Iowa Code section 633A.4504 (2005) 1 to support their motion to dismiss.”
Kenneth W. Turner Vs. Iowa State Bank & Trust Co. Of Fairfield, Iowa, & Earl Wallace Dick (Iowa 2007). · cites it 16× “The co-trustees relied on 3 Iowa Code section 633A.4504 (2005)1 to support their motion to dismiss.”
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust (Iowa Ct. App. 2018). · cites it 9× “The defendants argue the plaintiffs’ action is untimely under Iowa Code section 633A.4504 (2017), which applies only to breach-of-trust claims.”
In the Matter of the Trust of Duane M. Pagel (Iowa Ct. App. 2024). · cites it 2× ““A ruling is clearly unreasonable or untenable when it is ‘not supported by 5 This ruling was pursuant to Iowa Code section 633A.4504(1) (2019), which establishes the one-year statute of limitations for claims against a trustee for breach of trust.”
— Iowa Code § 633A.4504(1) — 5 cases
Turner v. Iowa State Bank & Trust Co. of Fairfield, 743 N.W.2d 1 (Iowa 2007). “The co-trustees relied on Iowa Code section 633A.4504 (2005) 1 to support their motion to dismiss.”
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust, 925 N.W.2d 620 (Iowa 2019). “Second, the defendants maintain Konrardy's and Burmeister's claims fail on the merits because the language of the trust "clearly and unambiguously" requires their share of the trust to be valued as of the date of Angerer's death rather than at the time of distribution. We…”
Kenneth W. Turner Vs. Iowa State Bank & Trust Co. Of Fairfield, Iowa, & Earl Wallace Dick (Iowa 2007). “The co-trustees relied on 3 Iowa Code section 633A.4504 (2005)1 to support their motion to dismiss.”
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust (Iowa Ct. App. 2018). “The defendants argue the plaintiffs’ action is untimely under Iowa Code section 633A.4504 (2017), which applies only to breach-of-trust claims.”
In the Matter of the Trust of Duane M. Pagel (Iowa Ct. App. 2024). ““A ruling is clearly unreasonable or untenable when it is ‘not supported by 5 This ruling was pursuant to Iowa Code section 633A.4504(1) (2019), which establishes the one-year statute of limitations for claims against a trustee for breach of trust.”
— Iowa Code § 633A.4504(2) — 1 case
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust, 925 N.W.2d 620 (Iowa 2019). “Second, the defendants maintain Konrardy's and Burmeister's claims fail on the merits because the language of the trust "clearly and unambiguously" requires their share of the trust to be valued as of the date of Angerer's death rather than at the time of distribution. We…”
— Iowa Code § 633A.4504(2)(a) — 1 case
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust (Iowa Ct. App. 2018). “The defendants argue the plaintiffs’ action is untimely under Iowa Code section 633A.4504 (2017), which applies only to breach-of-trust claims.”
— Iowa Code § 633A.4504(4) — 1 case
Serena Konrardy & Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust & Dewitt Bank & Trust Co., as Tr. of the Vincent Angerer Trust, 925 N.W.2d 620 (Iowa 2019). “Second, the defendants maintain Konrardy's and Burmeister's claims fail on the merits because the language of the trust "clearly and unambiguously" requires their share of the trust to be valued as of the date of Angerer's death rather than at the time of distribution. We…”
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