Iowa Code

Iowa Code § 669.23 (2026)

Employee liability

✓ current as of July 2026

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Employees of the state are not personally liable for any claim which is exempted under section 669.14. 84 Acts, ch 1259, §4 C85, §25A.23 C93, §669.23

Notes of Decisions

Cited in 9 cases (1 in the last 5 years), 1995–2025 · leading case: Dickerson v. Mertz, 547 N.W.2d 208 (Iowa 1996).

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Dickerson v. Mertz, 547 N.W.2d 208 (Iowa 1996). · cites it 16× “See Iowa Code §§ 669.23 , *213 669.14(4). Defendants do not, however, assert immunity with respect to plaintiffs intentional infliction of emotional distress claim.”

Hook v. Lippolt, 755 N.W.2d 514 (Iowa 2008). · cites it 4× “See Iowa Code § 669.23 (“Employees of the state are not personally liable for any claim which is exempted under section 669.”

Mcghee v. Pottawattamie Cnty., Ia, 475 F. Supp. 2d 862 (S.D. Iowa 2007). · cites it 2× “Iowa Code section 669.23 provides: “Employees of the state are not personally liable for any claim which is exempted under [Iowa Code] section 669.”

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 76× “23 (1985), now codified as amended at Iowa Code § 669.23 (2022)). C. Wagner v. State and Other Post-ITCA Caselaw.”

Kent v. Iowa, 651 F. Supp. 2d 910 (S.D. Iowa 2009). · cites it 2× “Iowa Code § 669.23 provides: “Employees of the state are not personally liable for any claim which is exempted under [Iowa Code] section 669.”

Mills v. Iowa Bd. of Regents, 770 F. Supp. 2d 986 (S.D. Iowa 2011). “It is equally apparent that Plaintiff cannot maintain an individual capacity claim against either Mason or Campbell for such claims, as § 669.23 of the ITCA provides that “[elm *997 ployees of the state are not personally liable for any claim which is exempted under section 669.”

Mumford v. Godfried, 52 F.3d 756 (8th Cir. 1995). “” Iowa Code Ann. § 669.23 . The district court therefore correctly concluded that it lacked subject matter jurisdiction as to Mumford’s common law tort claims.”

Pamela Sue Hook Vs. Carl Frederick Lippolt & The State Of Iowa (Iowa 2008). · cites it 5× “See Iowa Code § 669.23 (“Employees of the state are not personally liable for any claim which is exempted under section 669.”

Harrington v. Wilber, 670 F. Supp. 2d 958 (S.D. Iowa 2009). · cites it 9× “Plaintiff offers no support for the contention that this Court is less bound by principles of stare decisis merely because the Eighth Circuit, sitting in diversity with regard to McGhee’s defa *968 mation claim, applied Iowa law in a way with which Plaintiff disagrees.”

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