The Iowa Supreme Court unanimously affirmed a district court decision that largely sided with property management companies in a landlord-tenant dispute over rental unit showings, rejecting most claims by tenants Alex Butter and Sydney Stodola who alleged excessive trespassing by their landlords.
In *Alex Butter and Sydney Stodola v. Midwest Property Management IC, LLC, KMB Property Management, and Ruby Investments, LLC* (Iowa 2026), Chief Justice Christensen delivered the court's opinion affirming the lower court's findings with only minor modifications to the damages calculation.
The case originated in small claims court where Butter and Stodola sued their landlords for common law trespass after becoming frustrated with the frequency of rental unit showings to prospective tenants for the next rental period. The tenants argued that their landlords entered their unit without proper consent on multiple occasions while preparing to rent the property to new tenants.
The magistrate initially found that the tenants had demonstrated four occasions of common law trespass, including two incidents that occurred on the same day. As damages, the magistrate awarded the cost of three days of the tenants' rent. However, the court declined to award attorney fees under Iowa Code section 562A.12(8), determining that the statutory provision did not apply to the circumstances of this case.
When the case reached the district court level, the judge largely agreed with the magistrate's findings but modified the damages calculation. Instead of awarding three days' rent, the district court determined that the tenants were entitled to three-and-a-half days' rent in damages, adding an additional half-day's rent for the second trespass that occurred on the same day as another incident.
On appeal to the Iowa Supreme Court, the tenants challenged several aspects of the lower court's ruling. They argued that the district court should have found additional instances of trespass, contending that they were unaware they could withhold consent for their landlord to enter the property. The tenants also challenged the damages award and the decision not to award attorney fees under the relevant Iowa statute.
Chief Justice Christensen, writing for a unanimous court, rejected the tenants' arguments across the board. The court held that consent for landlord entry is based on what the tenants' actions led the landlord to reasonably believe, not on the tenants' subjective understanding of their rights to withhold consent.
The opinion establishes important precedent for Iowa landlord-tenant law, particularly regarding the standards for determining when a landlord's entry constitutes trespass. The court's analysis focused on objective standards of consent rather than tenants' subjective knowledge of their legal rights.
Christopher Warnock of The Iowa Landlord Tenant Project in Iowa City represented the appellants, while Patrick J. Ford of Pugh Hagan Prahm, PLC in Coralville argued for the property management companies.
The case highlights ongoing tensions in landlord-tenant relationships, particularly during lease transitions when landlords need to show properties to prospective tenants while current tenants remain in residence. The court's ruling suggests that landlords have considerable latitude to show rental properties as long as they can demonstrate reasonable belief that tenants have consented to entry.
The decision may have broader implications for tenant rights advocates who argue that tenants need stronger protections against intrusive landlord conduct. The court's rejection of the attorney fees claim under Iowa Code section 562A.12(8) also limits tenants' ability to recover legal costs in similar disputes.
For property managers and landlords, the ruling provides clearer guidance on acceptable practices for showing rental units during lease transitions. The court's focus on objective standards for determining consent gives landlords more predictable legal ground when scheduling property showings.
The case was submitted to the Iowa Supreme Court on November 4, 2025, with the opinion filed December 31, 2025, and amended January 6, 2026. The unanimous nature of the decision suggests the court viewed the legal standards as relatively clear despite the factual disputes between the parties.
The district court proceedings took place in Johnson County, with Magistrate Christopher Foster initially hearing the case before Judge Chad Kepros handled the district court review.
This decision adds to Iowa's body of landlord-tenant law precedent and will likely be cited in future disputes involving similar claims of trespass during property showings. The court's emphasis on objective consent standards may influence how both landlords and tenants approach communications about property access in the future.