Iowa Code » Chapter 669 — STATE TORT CLAIMS
Iowa Code

Iowa Code § 669.14A (2026)

Qualified immunity

✓ current as of July 2026
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1. Notwithstanding any other provision of law, an employee of the state subject to a claim brought under this chapter shall not be liable for monetary damages if any of the following apply:

a. The right, privilege, or immunity secured by law was not clearly established at the time \n Tue Dec 09 21:57:34 2025 Iowa Code 2026, Chapter 669 (37, 0) 7 STATE TORT CLAIMS, §669.18\n\nof the alleged deprivation, or at the time of the alleged deprivation the state of the law was not sufficiently clear that every reasonable employee would have understood that the conduct alleged constituted a violation of law.

b. A court of competent jurisdiction has issued a final decision on the merits holding, without reversal, vacatur, or preemption, that the specific conduct alleged to be unlawful was consistent with the law.

2. The state or a state agency shall not be liable for any claim brought under this chapter where the employee was determined to be protected by qualified immunity under subsection 1.

3. A plaintiff who brings a claim under this chapter alleging a violation of the law must state with particularity the circumstances constituting the violation and that the law was clearly established at the time of the alleged violation. Failure to plead a plausible violation or failure to plead that the law was clearly established at the time of the alleged violation shall result in dismissal with prejudice.

4. Any decision by the district court denying qualified immunity shall be immediately appealable.

5. This section shall apply in addition to any other statutory or common law immunity. 2021 Acts, ch 183, §12, 16 \n

Notes of Decisions
Cited in 11 cases (11 in the last 5 years), 2023–2026 · leading case: Sara Montague, individually, & as parent & next friend of C.M., a minor, & as the duly authorized Rep. of the Est. of Robert McFarland v. Beth Skinner, William Sperfslage, Samantha Tucker-Sieberg, Sarah Holder, Daniel Clark, Jeremy Larson, Michael Heinricy, Chad Kerker, Scott Eschen, Brian Tracy, Robert Hartig, Josh Baal, Tracy Dietsch, Jeremy Burds, Jon Day, Lucas Fowler (Iowa 2026).
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Sara Montague, individually, & as parent & next friend of C.M., a minor, & as the duly authorized Rep. of the Est. of Robert McFarland v. Beth Skinner, William Sperfslage, Samantha Tucker-Sieberg, Sarah Holder, Daniel Clark, Jeremy Larson, Michael Heinricy, Chad Kerker, Scott Eschen, Brian Tracy, Robert Hartig, Josh Baal, Tracy Dietsch, Jeremy Burds, Jon Day, Lucas Fowler (Iowa 2026). · cites it 36× “183, §§ 12, 14 (codified at Iowa Code § 669.14A (2022); id. § 670.4A).”
John Larson v. Chad Holmes (Iowa Ct. App. 2025). · cites it 20× “14A(3) as the provisions “were enacted at the same time,” “are identical,” and “our holding in Doe that substantive qualified immunity applies only to statutory or constitutional claims and not to common law claims applies equally to section 669.14A.” Est. of Kahn v. City of…”
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). · cites it 8× “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). · cites it 8× “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). · cites it 8× “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
Cory Burnett v. Phillip Smith & State of Iowa (Iowa 2023). · cites it 5× “Additionally, the State argued that the recently-enacted immunity in Iowa Code section 669.14A barred all claims. The State also asked that Burnett’s punitive damages claim be dismissed even if some of his claims otherwise withstood summary judgment.”
Cory Burnett v. Phillip Smith & State of Iowa (Iowa 2023). · cites it 5× “Additionally, the State argued that the recently-enacted immunity in Iowa Code section 669.14A barred all claims. The State also asked that Burnett’s punitive damages claim be dismissed even if some of his claims otherwise withstood summary judgment.”
Est. of Sharon Kahn & Suzanne L. Rowe, as Adm'r of The Est. of Sharon Kahn, & Est. Of Vicki Hodges & Suzanne L. Rowe & Sierra D. Reyes, as Co-Administrators of the Est. of Vicki Hodges v. City of Clermont, Iowa, Fayette Cnty. Conservation Bd., Fayette Cnty., Iowa, & State of Iowa (Iowa 2025). · cites it 4× “4A (the Municipal Tort Claims Act) and § 669.14A (the State Tort Claims Act). Each tort claim statute generally subjects the state or a municipality to liability for its torts and those of its officers and employees acting within the scope of their employment or duties.”
Eugene Sikora v. State of Iowa & Dr. Beth Skinner, in her Off. capacity as Dir. of the Iowa Dep't of Corr. (Iowa 2025). · cites it 4× “The defendants moved to dismiss Sikora’s suit on three grounds: (1) all of Sikora’s claims are essentially false imprisonment claims, which are barred by sovereign immunity; (2) Godfrey claims under article I, sections 1 and 8 are not cognizable; and (3) the defendants are…”
Bert Miller & Nancy Duffner v. State of Iowa (Iowa 2025). · cites it 2× “2d 245 (Iowa 5Iowa Code section 669.14A(1)(a) provides: Notwithstanding any other provision of law, an employee of the state subject to a claim brought under this chapter shall not be liable for monetary damages if any of the following apply .”
Lisa Boggess, as Adm'r of the Est. of Brent Boggess, & as next friend to minors Z.B. & J.B., Drake L. Boggess, individually, & Kim Buttshaw, individually v. City of Waterloo & Kenneth Schaff (Iowa 2026). “3d 213 , 218 (Iowa 2026) (following Doe to hold the “essentially identical” immunity provision in § 669.14A of the Iowa Tort Claims Act does not apply to common law claims).”
— Iowa Code § 669.14A(1)(a) — 1 case
Bert Miller & Nancy Duffner v. State of Iowa (Iowa 2025). “2d 245 (Iowa 5Iowa Code section 669.14A(1)(a) provides: Notwithstanding any other provision of law, an employee of the state subject to a claim brought under this chapter shall not be liable for monetary damages if any of the following apply .”
— Iowa Code § 669.14A(2) — 3 cases
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, & State of Iowa & Gerd Clabaugh, Sarah Reisetter, & Susan Dixon (Iowa 2023). “But unlike the situation in Nahas, Carver-Kimm filed her initial petition almost nine months before section 669.14A went into effect. Her first motion to amend, which added count II’s claim for the wrongful discharge tort, was simi- larly filed about two weeks before the statute…”
— Iowa Code § 669.14A(3) — 2 cases
John Larson v. Chad Holmes (Iowa Ct. App. 2025). “14A(3) as the provisions “were enacted at the same time,” “are identical,” and “our holding in Doe that substantive qualified immunity applies only to statutory or constitutional claims and not to common law claims applies equally to section 669.14A.” Est. of Kahn v. City of…”
Sara Montague, individually, & as parent & next friend of C.M., a minor, & as the duly authorized Rep. of the Est. of Robert McFarland v. Beth Skinner, William Sperfslage, Samantha Tucker-Sieberg, Sarah Holder, Daniel Clark, Jeremy Larson, Michael Heinricy, Chad Kerker, Scott Eschen, Brian Tracy, Robert Hartig, Josh Baal, Tracy Dietsch, Jeremy Burds, Jon Day, Lucas Fowler (Iowa 2026). “183, §§ 12, 14 (codified at Iowa Code § 669.14A (2022); id. § 670.4A).”
— Iowa Code § 669.14A(4) — 1 case
Sara Montague, individually, & as parent & next friend of C.M., a minor, & as the duly authorized Rep. of the Est. of Robert McFarland v. Beth Skinner, William Sperfslage, Samantha Tucker-Sieberg, Sarah Holder, Daniel Clark, Jeremy Larson, Michael Heinricy, Chad Kerker, Scott Eschen, Brian Tracy, Robert Hartig, Josh Baal, Tracy Dietsch, Jeremy Burds, Jon Day, Lucas Fowler (Iowa 2026). “183, §§ 12, 14 (codified at Iowa Code § 669.14A (2022); id. § 670.4A).”
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