The Iowa Supreme Court Rules on Undue Influence and Lack of Capacity

Posted on: November 6th, 2024

An elderly woman and her long-time friend raised hogs in a partnership. The woman deeded half of her interest in the land to her friend. Over a decade later, the woman deeded the rest of her interest in the land. Both deeds were done with nothing in return from the friend. Approximately six months later, the woman’s adult daughters were appointed as her conservator and her guardian. The validity of the quitclaim deed was challenged by the conservator based on undue influence and lack of capacity. The district court found that there was undue influence through a confidential relationship, and, even if not, the woman lacked the necessary capacity to deed her interest in the land. The court of appeals, although divided, affirmed on the basis of lack of capacity. The Iowa Supreme Court granted the friend’s application to clarify the extent to which Iowa law permits donors to make their own decisions, even when an outsider may view the gift as misplaced. Based on the examination of the record and Iowa case law, the Iowa Supreme Court found that the conservator did not establish by clear, convincing, and satisfactory evidence that there was undue influence or that the woman lacked capacity at the time of the gift. The court of appeals decision was vacated, and the judgment from the district court was reversed and remanded.

Case No. 22-1905: Conservatorship of Janice Geerdes by Laura Jenkins, v. Albert Gomez Cruz.

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