Iowa Code

Iowa Code § 649.6 (2026)

Equitable proceedings

✓ current as of July 2026
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In all other respects, the action contemplated in this chapter shall be conducted as other actions by equitable proceedings, so far as the same may be applicable, with the modifications prescribed. [C51, §2026; R60, §3604; C73, §3276; C97, §4227; C24, 27, 31, 35, 39, §12290; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §649.6]

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Notes of Decisions
Cited in 13 cases (5 in the last 5 years), 1971–2026 · leading case: Baratta v. Polk Cnty. Health Servs., Inc., 588 N.W.2d 107 (Iowa 1999).
Baratta v. Polk Cnty. Health Servs., Inc., 588 N.W.2d 107 (Iowa 1999). · cites it 4× “Scope and Standard of Review Sandra Baratta filed a petition in equity for foreclosure of a judgment lien. As a counterclaim to Sandra's foreclosure action, PCHS brought an action to quiet title.”
Moser v. Thorp Sales Corp., 312 N.W.2d 881 (Iowa 1981). · cites it 2× “§ 649.6, The Code 1981. As such, our review is de novo.”
Rouse v. Union Twp., 530 N.W.2d 714 (Iowa 1995). · cites it 2× “It is from this ruling that the Rouses appeal.”
Larry Schaefer & Elaine Schaefer, Husband & Wife v. Raymond Schaefer v. Larry Schaefer & Elaine Schaefer, Husband & Wife, 795 N.W.2d 494 (Iowa 2011). “§ 649.6 (classifying quiet title action as equitable).”
State Ex Rel. Iowa Dep't of Nat. Resources v. Burlington Basket Co., 651 N.W.2d 29 (Iowa 2002). · cites it 2× “Accordingly, the court denied the State’s request to quiet title and to enjoin BBC from future activities on the island.”
Costello v. Costello, 186 N.W.2d 651 (Iowa 1971). · cites it 2× “He also said, “Well, in my opinion she was so incompetent mentally that she wouldn’t realize what she was doing, whether it be a legal document or any other kind of a document, and I don’t pretend to be a lawyer, but my medical opinion is that she was utterly incapable of doing…”
Hosteng Concrete & Gravel, Inc. v. Tullar, 524 N.W.2d 445 (Iowa Ct. App. 1994). · cites it 2× “Iowa Code § 649.6 (1993). In this equity action our review is de novo.”
Krotz v. Sattler, 586 N.W.2d 336 (Iowa 1998). · cites it 2× “2d 158, 161 (Iowa 1996); see Iowa Code § 649.6 (1997) (except for recovery of attorney fees, action to quiet title shall be conducted as equitable proceeding).”
Poweshiek Twp. v. Gannon (Iowa Ct. App. 2021). · cites it 2× “See Iowa Code § 649.6 . Our review is de novo.”
Duke Carter v. Mike Fricke & Laura Fricke (Iowa Ct. App. 2024). · cites it 2× “2d 379 , 380–81 (Iowa 1980); see also Iowa Code § 649.6 (providing that quiet-title action “shall be conducted as other actions by equitable proceedings”).”
Mark Fink & Stacy Fink v. Donald Lawson & Linda Lawson (Iowa Ct. App. 2025). · cites it 2× “Because the tort claims raised in the Finks’ petition have not been resolved, our supreme court treated their notice of appeal as an application for interlocutory review, granted the application, and transferred the appeal to this court.”
Kleinendorst v. Est. of Kleinendorst (Iowa Ct. App. 2026). · cites it 2× “After a second hearing, the district court granted the motion to reconsider and concluded that section 633.”
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