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

Iowa Code § 648.15 (2026)

How title tried

✓ current as of July 2026
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When title is put in issue, the cause shall be tried by equitable proceedings. [C97, §4216; C24, 27, 31, 35, 39, §12276; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §648.15] Referred to in §648.17\n\nTue Dec 09 21:58:15 2025 Iowa Code 2026, Chapter 648 (21, 0) §648.16, FORCIBLE ENTRY AND DETAINER 4

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Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 1969–2023 · leading case: Gary N. Porter & Lori Porter v. Richard L. Harden & Janice Harden, 891 N.W.2d 420 (Iowa 2017).
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Gary N. Porter & Lori Porter v. Richard L. Harden & Janice Harden, 891 N.W.2d 420 (Iowa 2017). · cites it 4× “________________________ Where an occupant of real estate has color of title thereto and has in good faith made valuable improvements thereon, and is thereafter adjudged not to be the owner, no execution shall issue to put the owner of the land in possession of the same, after…”
Garrison v. Fetters, 383 N.W.2d 550 (Iowa 1986). · cites it 6× “See Iowa Code § 648.15 (“When title is put in issue, the [forcible entry and detainer] cause shall be tried in equity.”
Larry Schaefer & Elaine Schaefer, Husband & Wife v. Raymond Schaefer v. Larry Schaefer & Elaine Schaefer, Husband & Wife, 795 N.W.2d 494 (Iowa 2011). · cites it 2× “Iowa Code § 648.15 (classifying forcible entry and detainer actions as equitable); id.”
Steele v. Northup, 168 N.W.2d 785 (Iowa 1969). · cites it 2× “When title is put in issue the cause shall be tried (in district court) by equitable proceedings, section 648.15. *788 A careful study of the foregoing statutes with due regard to the history of their amendments indicates that title is a justiciable issue in a forcible entry and…”
Jenkins v. Clark (Iowa Ct. App. 2022). · cites it 4× “See Iowa Code § 648.15 (“When title is put in issue, the [forcible entry and detainer] cause shall be tried in equity.”
Amended May 23, 2017 Gary N. Porter & Lori Porter v. Richard L. Harden & Janice Harden (Iowa 2017). · cites it 2× “________________________ Where an occupant of real estate has color of title thereto and has in good faith made valuable improvements thereon, and is thereafter adjudged not to be the owner, no execution shall issue to put the owner of the land in possession of the same, after…”
No Boundry, LLC v. Brandi Smithson (Iowa Ct. App. 2023). · cites it 2× “See Iowa Code § 648.15 ; Iowa R. App. P. 6.907; ACC Holdings v.”
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