Iowa Code » Chapter 670 — TORT LIABILITY OF GOVERNMENTAL SUBDIVISIONS
Iowa Code

Iowa Code § 670.1 (2026)

Definitions

✓ current as of July 2026
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As used in this chapter, the following terms shall have the following meanings:

1. “Governing body” means the council of a city, county board of supervisors, board of township trustees, local school board, and other boards and commissions exercising quasi-legislative, quasi-executive, and quasi-judicial power over territory comprising a municipality.

2. “Municipality” means city, county, township, school district, a chapter 28E entity as provided in section 670.4, subsection 1, paragraph “p”, and any other unit of local government except soil and water conservation districts as defined in section 161A.3, subsection 6.

3. “Officer” includes but is not limited to the members of the governing body.

4. “Tort” means every civil wrong which results in wrongful death or injury to person or injury to property or injury to personal or property rights and includes but is not restricted to actions based upon negligence; error or omission; nuisance; breach of duty, whether statutory or other duty or denial or impairment of any right under any constitutional provision, statute or rule of law. [C71, 73, 75, 77, 79, 81, §613A.1] 86 Acts, ch 1172, §2; 86 Acts, ch 1238, §61; 87 Acts, ch 23, §57; 89 Acts, ch 83, §82 C93, §670.1 2015 Acts, ch 132, §48, 51 Referred to in §29C.9, 87.4, 321.231A, 321.231B, 321.424, 321.433, 321.451, 554G.1 \n

Notes of Decisions
Cited in 48 cases (13 in the last 5 years), 1947–2025 · leading case: Joshua Venckus v. City of Iowa City, 930 N.W.2d 792 (Iowa 2019).
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Joshua Venckus v. City of Iowa City, 930 N.W.2d 792 (Iowa 2019). · cites it 4× “” Iowa Code section 670.1(4) defines a “tort” as “every civil wrong,” including the “denial or impairment of any right under any constitutional provision.”
Joshua N. Thomas v. Officers Tim Gavin, Chuck Tygart, Jess Bernhard, & Adam Olson Deputy Sheriff Luke Hruby Reserve Deputy Sheriff Joshua Gersten the City of North Liberty, Iowa & Johnson Cnty., Iowa, 838 N.W.2d 518 (Iowa 2013). · cites it 3× “405 § 1(2); Iowa Code § 670.1 (1). 3 . Article III, section 29 provides: "Every act shall embrace but one subject, and matters *525 properly connected therewith; which subject shall be expressed in the title.”
Gregory Baldwin v. City of Estherville, Iowa, 929 N.W.2d 691 (Iowa 2019). · cites it 4× “Iowa Code § 670.1 (4) (2019) (emphasis added).”
Rucker v. Humboldt Cmty. Sch. Dist., 737 N.W.2d 292 (Iowa 2007). · cites it 4× “Humboldt Community School District and Humboldt High School are "municipalities" as defined by Iowa Code section 670.1(2). Rucker's claims against Hoffman are also subject to Iowa Code chapter 670 because Hoffman is being sued in his capacity as a municipal employee.”
Keystone Elec. Mfg., Co. v. City of Des Moines, 586 N.W.2d 340 (Iowa 1998). · cites it 4× “See Iowa Code § 670.1 (1993). 2 . A "tort” is defined as "every civil wrong which results in .”
Iowa Coal Mining Co. v. Monroe Cnty., 555 N.W.2d 418 (Iowa 1996). · cites it 2× “) Iowa Code section 670.1 defines a municipality to include a county.”
Perkins Ex Rel. Perkins v. Dallas Ctr.-Grimes Cmty. Sch. Dist., 727 N.W.2d 377 (Iowa 2007). · cites it 4× “The school district is a municipal defendant, as defined by Iowa Code section 670.1(2), a part of our Municipal Tort Claims Act.”
Kelley v. Story Cnty. Sheriff, 611 N.W.2d 475 (Iowa 2000). · cites it 4× “4(7) and (8), when read with the definition of "tort," now codified at section 670.1(4), would violate article I, section 18 of the Iowa Constitution as they would appear to exempt the county from liability for constitutional torts, i.”
Cedar Falls v. Cedar Falls Sch. Dist., 617 N.W.2d 11 (Iowa 2000). · cites it 2× “Iowa Code chapter 670 governs tort liability of governmental subdivisions, including school districts, see Iowa Code § 670.1 (2) (1999) (defining “municipality” to include a school district), subjecting them to liability for the torts of their officers and employees unless the…”
Jane Doe v. New London Cmty. Sch. Dist., 848 N.W.2d 347 (Iowa 2014). · cites it 2× “§ 670.1(2) (“Municipality” means city, county, township, school district, and any other unit of local government .”
City of McGregor v. Janett, 546 N.W.2d 616 (Iowa 1996). · cites it 3× “§ 670.1(1). Thus Iowa’s law appears consistent with the general rule that “[a] municipality may be charged with responsibility for misrepresen *620 tations of its agent.”
Wilma Jean Kellogg v. City of Albia, Iowa, 908 N.W.2d 822 (Iowa 2018). · cites it 2× “Iowa Code § 670.1 (4) (" ' Tort ' means every civil wrong which results in wrongful death or injury to person or injury to property or injury to personal or property rights and includes but is not *827 restricted to actions based upon negligence; error or omission; nuisance .”
Show all 48 citing cases →
— Iowa Code § 670.1(1) — 3 cases
City of McGregor v. Janett, 546 N.W.2d 616 (Iowa 1996). “§ 670.1(1). Thus Iowa’s law appears consistent with the general rule that “[a] municipality may be charged with responsibility for misrepresen *620 tations of its agent.”
Nicholas Breuer v. West Burlington Indep. Sch. Dist. (Iowa Ct. App. 2020).
William & Mary Goche, LLC, Global Assets, LLC, & Joseph Goche v. Kossuth Cnty. Bd. of Supervisors in their capacity as Trs. of Drainage Districts 4, 18, & 80, Roger Tjarks, Pam Wymore, Kyle Stecker, Jack Plathe, Gene Elssbecker, Galen Casey, Donnie Loss, Don McGregor, & Don Besch (Iowa 2024).
— Iowa Code § 670.1(2) — 11 cases
Rucker v. Humboldt Cmty. Sch. Dist., 737 N.W.2d 292 (Iowa 2007). “Humboldt Community School District and Humboldt High School are "municipalities" as defined by Iowa Code section 670.1(2). Rucker's claims against Hoffman are also subject to Iowa Code chapter 670 because Hoffman is being sued in his capacity as a municipal employee.”
Perkins Ex Rel. Perkins v. Dallas Ctr.-Grimes Cmty. Sch. Dist., 727 N.W.2d 377 (Iowa 2007). “The school district is a municipal defendant, as defined by Iowa Code section 670.1(2), a part of our Municipal Tort Claims Act.”
Jane Doe v. New London Cmty. Sch. Dist., 848 N.W.2d 347 (Iowa 2014). “§ 670.1(2) (“Municipality” means city, county, township, school district, and any other unit of local government .”
Joshua N. Thomas v. Officers Tim Gavin, Chuck Tygart, Jess Bernhard, & Adam Olson Deputy Sheriff Luke Hruby Reserve Deputy Sheriff Joshua Gersten the City of North Liberty, Iowa & Johnson Cnty., Iowa, 838 N.W.2d 518 (Iowa 2013). “405 § 1(2); Iowa Code § 670.1 (1). 3 . Article III, section 29 provides: "Every act shall embrace but one subject, and matters *525 properly connected therewith; which subject shall be expressed in the title.”
Kulish v. Ellsworth, 566 N.W.2d 885 (Iowa 1997).
— Iowa Code § 670.1(3) — 2 cases
City of McGregor v. Janett, 546 N.W.2d 616 (Iowa 1996). “§ 670.1(1). Thus Iowa’s law appears consistent with the general rule that “[a] municipality may be charged with responsibility for misrepresen *620 tations of its agent.”
Nicholas Breuer v. West Burlington Indep. Sch. Dist. (Iowa Ct. App. 2020).
— Iowa Code § 670.1(4) — 9 cases
Joshua Venckus v. City of Iowa City, 930 N.W.2d 792 (Iowa 2019). “” Iowa Code section 670.1(4) defines a “tort” as “every civil wrong,” including the “denial or impairment of any right under any constitutional provision.”
Kelley v. Story Cnty. Sheriff, 611 N.W.2d 475 (Iowa 2000). “4(7) and (8), when read with the definition of "tort," now codified at section 670.1(4), would violate article I, section 18 of the Iowa Constitution as they would appear to exempt the county from liability for constitutional torts, i.”
Wilma Kellogg v. City of Albia, Iowa (Iowa Ct. App. 2017).
Wilma Jean Kellogg v. City of Albia, Iowa (Iowa 2018).
William McClellan & Racquel McClellan, Individually & as Next Friend for Minor Child, R.B. v. Pablo Orlando Ramirez, & the City of Dubuque, Iowa (Iowa Ct. App. 2019).
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