Iowa Code

Iowa Code § 648.18 (2026)

Possession — bar

✓ current as of July 2026

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Thirty days’ peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to this proceeding. [C51, §2372; R60, §3962; C73, §3621; C97, §4217; C24, 27, 31, 35, 39, §12279; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §648.18] Referred to in §648.22A, 648.22B

Notes of Decisions

Cited in 18 cases (2 in the last 5 years), 1946–2025 · leading case: Petty v. Faith Bible Christian Outreach Ctr., Inc., 584 N.W.2d 303 (Iowa 1998).

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Petty v. Faith Bible Christian Outreach Ctr., Inc., 584 N.W.2d 303 (Iowa 1998). · cites it 22× “We affirm the lower courts’ findings that the lease was not automatically renewed but conclude the FED action was barred under Iowa Code section 648.18 (1995). I. Background Facts and Proceedings.”

Kaydon Acquisition Corp. v v. Am. Cent. Indus., Inc., 179 F. Supp. 2d 1022 (N.D. Iowa 2001). · cites it 12× “Alternatively, even if the court were to assume, arguendo, that ACI had established that the conditions shown in ACI’s photographic exhibits constitute a violation of the Lease, the court concludes that this portion of ACI’s forcible detainer and entry action is barred under…”

Bernet v. Rogers, 519 N.W.2d 808 (Iowa 1994). · cites it 6× “See Iowa Code § 648.18 (“Thirty days’ peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to a [forcible entry and detainer] proceeding.”

Roshek Realty Co. v. Roshek Bros. Co., 87 N.W.2d 8 (Iowa 1957). · cites it 4× “Code section 648.18 provides: “Thirty days peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to this proceeding.”

Morling v. Schmidt, 299 N.W.2d 480 (Iowa 1980). · cites it 5× “Although finding defendant’s possession was unlawful, the trial court held plaintiff had failed to bring his action within thirty days from the date defendant wrongfully entered the premises (§ 648.18, The Code) and dismissed the petition.”

Town of Lakota v. Gray, 35 N.W.2d 841 (Iowa 1949). · cites it 6× “Defendant claims the petition shows on its face the action is barred under Code section 648.18 which provides: “Thirty days peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to this proceeding.”

Warren v. Yocum, 223 N.W.2d 258 (Iowa 1974). · cites it 4× “Code § 648.18 says: “Thirty days peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to this proceeding.”

Rudolph v. Davis, 25 N.W.2d 332 (Iowa 1946). · cites it 4× “The court thereupon, on May 2, 1946, entered order, judgment, and decree sustaining defendants’ motion to dismiss, and stated, in its finding and order therefor, that defendants had been in peaceable possession since March 1, 1946, until the service of the notice (to quit) on…”

Garrison v. Fetters, 383 N.W.2d 550 (Iowa 1986). · cites it 4× “15 (1983), which provides that forcible entry actions are to be tried in equity, unconstitutionally denied them a trial by jury; (2) the thirty-day “peaceable possession” exception of Iowa Code section 648.18 was applicable, thus barring the action; (3) the notice to cure, under…”

Hillview Assocs. v. Bloomquist, 440 N.W.2d 867 (Iowa 1989). · cites it 2× “The tenants also raised the affirmative defense of waiver based upon Iowa Code section 648.18. This section provides thirty days peaceable possession with the knowledge of the landlord after the cause of action accrues is a bar to a forcible entry or detention proceeding.”

Thomas v. Brodsack, 215 N.W.2d 503 (Iowa 1974). · cites it 5× “Defendants contend plaintiffs’ forcible entry and detainer action was barred by the limitation of Code § 648.18, which provides: “Thirty days peaceable possession with the knowledge of the plaintiff after the cause of action accrues is a bar to this proceeding.”

Bates v. Bates, 24 N.W.2d 460 (Iowa 1946). · cites it 2× “It follows that appellants’ further contention that their thirty days’ peaceable possession after its service was a bar to further proceedings (under section 648.18, Code, 1946, section 12279, Code, 1939) is without merit.”

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