Iowa Code » Chapter 85 — WORKERS’ COMPENSATION
Iowa Code

Iowa Code § 85.18 (2026)

Contract to relieve not operative

✓ current as of July 2026
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A contract, rule, or device shall not operate to relieve the employer, in whole or in part, from any liability created by this chapter except as provided in this chapter. This section does not create a private cause of action. [S13, §2477-m7; C24, 27, 31, 35, 39, §1378; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §85.18] 2017 Acts, ch 23, §2, 24; 2023 Acts, ch 66, §13

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Notes of Decisions
Cited in 31 cases (2 in the last 5 years), 1958–2024 · leading case: Smith v. Smithway Motor Xpress, Inc., 464 N.W.2d 682 (Iowa 1990).
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Smith v. Smithway Motor Xpress, Inc., 464 N.W.2d 682 (Iowa 1990). · cites it 8× “The public policy involved in this case is expressed in Iowa Code section 85.18 (1985), which provides: “[n]o contract, rule, or device whatsoever shall operate to relieve the employer, in whole or in part, from any liability created by this chapter except as herein provided.”
Hanna v. Fleetguard, Inc., 900 F. Supp. 1110 (N.D. Iowa 1995). · cites it 17× “First, Hanna asserts that her retaliatory discharge claim ¿gainst Fleetguard and Liberty Mutual is a clairP arising under Iowa Code § 85.18 , a statute' ?/bich is part of Iowa’s workers’ compensation law: 28 U.”
Springer v. Weeks & Leo Co., Inc., 429 N.W.2d 558 (Iowa 1988). · cites it 4× “It is provided in Iowa Code section 85.18 (1987) that: No contract, rule, or device whatsoever shall operate to relieve the employer, in whole or in part, from any liability created by this chapter except as herein provided.”
Teachout v. Forest City Cmty. Sch. Dist., 584 N.W.2d 296 (Iowa 1998). · cites it 4× “at 560 (quoting Iowa Code § 85.18 (1987)). We observed that to permit the retaliatory discharge alleged in Springer “would fly in the face of this policy.”
Grundmeyer v. Weyerhaeuser Co., 649 N.W.2d 744 (Iowa 2002). · cites it 4× “” Iowa Code § 85.18 . On July 19, 2000, Grundmeyer filed a petition for judicial review in the district court.”
Ballalatak v. All Iowa Agric. Ass'n, 781 N.W.2d 272 (Iowa 2010). · cites it 4× “The court relied upon Iowa Code section 85.18 (1987), which provides, “[n]o contract, rule, or device whatsoever shall operate to relieve the employer, in whole or in part, from any liability created by this chapter except as herein provided.”
Beekman v. Nestle Purina Petcare Co., 635 F. Supp. 2d 893 (N.D. Iowa 2009). · cites it 5× “” Iowa Code § 85.18 . Second, in Springer v.”
Napreljac v. John Q. Hammons Hotels, Inc., 461 F. Supp. 2d 981 (S.D. Iowa 2006). · cites it 3× “The court found such a policy in Iowa Code section 85.18, which provided that “ ‘[n]o contract, rule, or device whatsoever shall operate to relieve the employer, in whole or in part, from any liability created by [chapter 85 of the Iowa Code 34 ] except as herein provided.”
Springer v. Weeks & Leo Co., Inc., 475 N.W.2d 630 (Iowa 1991). · cites it 2× “We found Iowa Code section 85.18 was a clear expression that the public policy of this state is that an employee’s right to seek the compensation which is granted for work-related injuries should not be interfered with regardless of the terms of the contract of hire.”
Niesent v. Homestake Mining Co. of California, 505 N.W.2d 781 (S.D. 1993). · cites it 2× “Iowa Code § 85.18 (1987) provided: No contract, rule, or device whatsoever shall operate to relieve the employer, in whole or in part, from any liability created by this chapter except as herein provided.”
Graves v. O'HARA, 576 N.W.2d 625 (Iowa Ct. App. 1998). · cites it 4× “In Spñnger, the court stated, “[w]e deem this [Iowa Code section 85.18] 1 to be a clear expression that it is the public policy of this state that an employee’s right to seek the compensation which is granted by law for work-related injuries should not be inter *629 fered with…”
Below v. Skarr, 569 N.W.2d 510 (Iowa 1997). · cites it 2× “The policy on which Below relies stems from Iowa Code section 85.18 (1995), which provides: No contract, rule, or device whatsoever shall operate to reHeve the employer, in whole or in part, from any Habihty created by [the workers’ compensation] chapter except as herein…”
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