Your state’s pack. New issues arrive periodically on Mondays. Bookmark it. I built this for the Iowa T&E solo who knows Iowa Code ch. 633 (Iowa’s own Probate Code, Title XV) cold but still loses an afternoon a week hunting the current homestead posture, the Iowa Medicaid / IA Health Link estate-recovery reach, whether the Iowa bar’s latest ethics opinion changes how you scope an engagement, or whether a recent Iowa Court of Appeals decision just moved the law on capacity, undue influence, or a trustee’s duties. What’s below is what mattered in Iowa lately — the week’s developments and the recent rulings from the bench.
For licensed attorneys. This pack is general legal information and professional commentary for practicing attorneys — it is not legal advice, does not apply to any specific matter, and creates no attorney-client relationship. Verify every authority against the cited primary source before relying on it with a client. Published by Mike Moss, a Utah-admitted attorney, as an AI-enablement information product; it is not an offer of legal services and is not a representation that the author is admitted to practice in your jurisdiction.
Three developments from the last several weeks that I think actually matter to an Iowa T&E solo. Each one has a read that lands on your practice specifically — and each one comes with the citation so you can verify the detail yourself before you use it with a client.
HF 2532 (91st G.A.), passed both chambers unanimously and signed May 2, 2026 as 2026 Iowa Acts ch. 1074, creates Iowa Code § 633A.6203: trust contests are triable at law, other trust-code matters in equity, and all orders and decrees of the court sitting in probate are final decrees as to the parties — effective on enactment, with the remainder of the act applying July 1, 2026. The Court of Appeals is already citing the new section (see this week’s From the Courts).
Appealability just changed under your feet: trust-proceeding orders that used to be interlocutory are now final decrees, which starts appellate clocks immediately. Calendar accordingly in every supervised trust matter, and read the omnibus’s attorney-fee changes before your next fee application.
Iowa HF 2532, 91st G.A., 2026 Iowa Acts ch. 1074 (signed May 2, 2026) · legis.iowa.gov
This slot holds the week’s second Iowa-specific development — a bill with a verifiable committee vote on the legislature’s record, a newly-issued Iowa bar ethics opinion, an Iowa bar section notice, or a Medicaid agency bulletin. The orchestrator populates it from primary sources and the tr-cite below carries the source URL so the reader can verify before using it with a client.
[Per-state why-it-matters paragraph lands here once the headline item is populated.]
[Primary-source citation with URL]
Per the Iowa State Bar Association’s legislative materials, SF 408 — which would have authorized a transfer-on-death deed for real property — again failed to advance in the 91st General Assembly, following an earlier HF 125 that died. Iowa’s transfer-on-death mechanism remains limited to securities under Iowa Code ch. 633D; there is still no beneficiary deed for real property.
For an Iowa T&E solo this is a live intake signal: every client who assumes a “TOD deed” will keep real estate out of probate — often after reading national content or using an out-of-state form — is wrong here, and the plan needs a revocable trust, joint tenancy, or life estate to reach the same result. It also means Iowa’s expanded estate recovery, which reaches non-probate assets, still has more to claw back. Re-file the question for the next session.
Iowa SF 408 (91st G.A.) — did not pass · LEGIS.IOWA.GOV · SF 408
Decisions that bind an Iowa practitioner — Iowa’s appellate courts and the federal courts covering Iowa, including the U.S. Eighth Circuit — read for what actually changes how you draft, advise, and plan. Trusts and estates broadly, not Medicaid alone: wills and capacity, undue influence, fiduciary duty, trust construction, and estate recovery. One read, the holding, and the official cite.
A settlor’s trust left half outright to one beneficiary, who also became sole trustee at death, and held the other half in trust for the second beneficiary. The second beneficiary sued for breach of trust under Iowa Code § 633A.4502. The trustee answered, invoked the court’s probate jurisdiction, applied for a successor, and resigned — and the district court, using Probate Code language, brought the trust under continuous court supervision, approved her final report, and declared her “released from any liability to Trust or its beneficiaries.” She then moved for summary judgment on the strength of that release. The district court reversed course, held the Trust Code governed, and denied the motion. The Court of Appeals affirmed. Section 633.10(4)(a)(2) reaches only a trust “established by court decree that is subject to continuous court supervision” — the phrase “that is” makes supervision a modifier, not an independent trigger — so a privately created trust stays under chapter 633A even after a court takes supervision. And § 633A.4106(2) is explicit: a resigning trustee’s liability for acts or omissions “is not released or affected by the trustee’s resignation.”
If you have ever cleared a departing trustee by getting the resignation, the successor appointment, and the final report approved in one tidy order, read § 633A.4106(2) again — the court cannot hand out that release, and neither the order nor the beneficiaries’ failure to object at the time will hold. The finality shortcut fails too: Iowa Code § 633.36, which makes probate orders final as to parties with notice, simply does not apply to a trust governed exclusively by the Trust Code. Note also the footnote — the same no-release language moved to § 633A.6203(2) as of May 2026, so check which numbering your instrument and your forms cite. The workable path for a trustee who wants out clean is a beneficiary release or a court-approved settlement on the merits, not a supervision order dressed up as a discharge.
In the Matter of the Tracy M. Dvorak Trust Dated September 10, 2019 (Dvorak v. Kochevar), No. 25-1450 (Iowa Ct. App. July 8, 2026) — affirmed. · IOWACOURTS.GOV · official opinion
The court affirmed that an inter vivos trust stays governed exclusively by Trust Code ch. 633A even after continuous supervision is invoked, and that under §633A.4106(2) a trustee’s resignation — and the order accepting it — does not release liability; the opinion’s footnote already applies new §633A.6203(2) (HF 2532) on finality of trust-proceeding orders.
Don’t let a trustee client rely on a probate-style discharge order — get beneficiary releases or a nonjudicial settlement agreement instead; and note the court is already applying the 2026 omnibus’s finality rule.
No. 25-1450, 2026 Iowa App. LEXIS 619 (Iowa Ct. App. July 8, 2026) · IOWACOURTS.GOV · official opinion
Reversed a district court’s cut of ordinary fees and total denial of extraordinary fees: reductions require detailed findings identifying duplicative or unreasonable entries, and §633.199 extraordinary services — tax issues, disputes affecting estate value — must be valued.
Your probate fee applications have fresh appellate backing: itemize time per task, bill extraordinary work separately, and challenge across-the-board reductions — courts must value what you did.
No. 25-0967, 2026 Iowa App. LEXIS 615 (Iowa Ct. App. July 8, 2026) · IOWACOURTS.GOV · official opinion
This week in Iowa for the T&E solo with Iowa Medicaid (IA Health Link) clients: the developments from the Iowa State Bar Association (Probate, Trust & Estate Planning Section) and Iowa Health and Human Services that actually moved your practice this period — each one primary-source verified.
Bar and Medicaid changes land on different schedules and aren’t indexed by practice focus. Every item here was checked against its primary source, with the link, so you can verify before relying on it.