Iowa Code » Chapter 648 — FORCIBLE ENTRY AND DETAINER
Iowa Code

Iowa Code § 648.1 (2026)

Grounds

✓ current as of July 2026
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A summary remedy for forcible entry and detainer is allowable:

1. Where the defendant has by force, intimidation, fraud, or stealth entered upon the prior actual possession of another in real property, and detains the same.

2. Where the lessee holds over after the termination of the lease.

3. Where the lessee holds contrary to the terms of the lease.

4. Where the defendant continues in possession after a sale by foreclosure of a mortgage, or on execution, unless the defendant claims by a title paramount to the lien by virtue of which the sale was made, or by title derived from the purchaser at the sale; in either of which cases such title shall be clearly and concisely set forth in the defendant’s pleading.

5. For the nonpayment of rent, when due.

6. When the defendant or defendants remain in possession after the issuance of a valid tax deed. [C51, §2362, 2363; R60, §3952, 3953; C73, §3611, 3612; C97, §4208; C24, 27, 31, 35, 39, §12263; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §648.1] 2004 Acts, ch 1101, §87 Referred to in §562A.26, 631.1, 648.3 \n

Notes of Decisions
Cited in 25 cases (4 in the last 5 years), 1946–2026 · leading case: Capital Fund 85 Ltd. P'ship v. Priority Sys., LLC, 670 N.W.2d 154 (Iowa 2003).
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Capital Fund 85 Ltd. P'ship v. Priority Sys., LLC, 670 N.W.2d 154 (Iowa 2003). · cites it 19× “See Iowa Code § 648.1 (2001). In particular, Capital Fund alleged Priority Systems has “by force, intimidation, fraud, or stealth entered upon [its] prior actual possession .”
Petty v. Faith Bible Christian Outreach Ctr., Inc., 584 N.W.2d 303 (Iowa 1998). · cites it 7× “” Iowa Code § 648.1 (2). However, a landlord who pursues this summary remedy is subject to the defense provided in Iowa Code section 648.”
Bernet v. Rogers, 519 N.W.2d 808 (Iowa 1994). · cites it 6× “See Iowa Code §§ 648.1 (2), (3), (4), (5), (6), 648.”
Robert's River Rides, Inc. v. Steamboat Dev. Corp., 520 N.W.2d 294 (Iowa 1994). · cites it 2× “The DNR reserved the right to terminate the lease “upon any of the grounds specified in Section 648.1 of the Code of Iowa or for violation of any terms of this lease.”
Kaydon Acquisition Corp. v v. Am. Cent. Indus., Inc., 179 F. Supp. 2d 1022 (N.D. Iowa 2001). · cites it 4× “Where the defendant continues in possession after a sale by foreclosure of a mortgage, or on execution, unless the defendant claims by a title paramount to the lien by virtue of which the sale was made, or by title derived from the purchaser at the sale; in either of which cases…”
Iowa Nat'l Mut. Ins. Co. v. Mitchell, 305 N.W.2d 724 (Iowa 1981). · cites it 2× ““Small claims” are limited to a “civil action for a money judgment where the amount in controversy is one thousand dollars or less, exclusive of interest and costs,” and “an action for forcible entry and de-tainer which is based on those grounds set forth in section 648.1,…”
Verlinden v. Godberson, 25 N.W.2d 347 (Iowa 1946). · cites it 4× “Section 648.1 of such chapter sets forth the grounds for such action.”
Polk Cnty. v. Davis, 525 N.W.2d 434 (Iowa Ct. App. 1994). · cites it 2× “Iowa Code § 648.1 (6) (1993). This provision applies to parties who are in possession of real property and is not limited to those who hold title to the property.”
Roshek Realty Co. v. Roshek Bros. Co., 87 N.W.2d 8 (Iowa 1957). · cites it 2× “(See Code section 648.1, subsections 2 and 3.) Pursuant to Code section 648.”
Reed v. Gaylord, 216 N.W.2d 327 (Iowa 1974). · cites it 2× “The question of title can only be investigated in the district court, and can be pleaded in a municipal court or a justice’s court only as provided in subsection 4 of section 648.1.” The subsection referred to in-the foregoing quote is in this language: “4.”
Robinson v. Black, 607 N.W.2d 676 (Iowa 2000). · cites it 4× “Iowa Code section 648.1 (1997) lists the grounds for which the remedy is allowable.”
Rudolph v. Davis, 30 N.W.2d 484 (Iowa 1948). · cites it 4× “(2) Plaintiff has not proven a case that falls within any of the grounds sot out in section 648.1, Code, 1946. (3) Plaintiff’s proper procedure would have been an action of right, which is an action at law, and the proceedings here cannot be interpreted to be proof under such…”
Show all 25 citing cases →
— Iowa Code § 648.1(1) — 1 case
Capital Fund 85 Ltd. P'ship v. Priority Sys., LLC, 670 N.W.2d 154 (Iowa 2003). “See Iowa Code § 648.1 (2001). In particular, Capital Fund alleged Priority Systems has “by force, intimidation, fraud, or stealth entered upon [its] prior actual possession .”
— Iowa Code § 648.1(2) — 3 cases
Petty v. Faith Bible Christian Outreach Ctr., Inc., 584 N.W.2d 303 (Iowa 1998). “” Iowa Code § 648.1 (2). However, a landlord who pursues this summary remedy is subject to the defense provided in Iowa Code section 648.”
Des Moines RHF Hous., Inc. v. Alvin Spencer, 919 N.W.2d 768 (Iowa Ct. App. 2018).
Gary N. Porter & Lori Porter v. Richard L. Harden & Janice Harden (Iowa Ct. App. 2016).
— Iowa Code § 648.1(3) — 1 case
Spataro v. Battani, 139 N.W.2d 396 (Iowa 1966).
— Iowa Code § 648.1(5) — 2 cases
Garrison v. Fetters, 383 N.W.2d 550 (Iowa 1986).
Seldin Co. v. Calabro, 702 N.W.2d 504 (Iowa Ct. App. 2005).
— Iowa Code § 648.1(6) — 1 case
No Boundry, LLC v. Brandi Smithson (Iowa Ct. App. 2023).
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