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Iowa Supreme Court Rules on Foreign Corporation Jurisdiction Requirements

The Iowa Supreme Court issued a unanimous ruling December 19, 2025, addressing whether foreign corporations must consent to personal jurisdiction when registering to do business in Iowa. The decision came in response to a certified question from a federal court handling a class action lawsuit against CRST transportation companies.

AI-generated Summary
4 min readcourtlistener
Seal of the Supreme Court of Iowa

Case Information

Case No.:
No. 25–0607

Key Takeaways

  • Iowa Supreme Court issued unanimous ruling on foreign corporation jurisdiction requirements
  • Federal court certified question about whether business registration equals consent to jurisdiction
  • Case involves class action lawsuit against multiple CRST transportation companies
  • Ruling will affect how out-of-state corporations understand legal exposure in Iowa

The Iowa Supreme Court delivered a unanimous opinion December 19, 2025, answering a certified question about whether foreign corporations consent to personal jurisdiction in Iowa courts simply by registering to do business in the state and appointing an agent for service of process.

The case, *Kelchner v. CRST Expedited Inc.*, arose from a class action lawsuit filed by Florida truck driver Harley Kelchner against multiple CRST transportation entities, including CRST Expedited Inc., CRST Specialized Transportation Inc., and CRST Lincoln Sales Inc. The lawsuit was filed in the U.S. District Court for the Northern District of Iowa.

The jurisdictional dispute began when the Indiana-based trucking company challenged personal jurisdiction in Iowa. Chief Judge C.J. Williams of the federal district court denied the company's motion to dismiss for lack of personal jurisdiction but granted the defendants' request to certify a question of Iowa law to the state's highest court.

The certified question asked: "Under Iowa law, does a foreign corporation consent to the personal jurisdiction of the Iowa courts by registering to do business in Iowa and appointing an agent for service of process in Iowa when a plaintiff then serves the foreign corporation's designated agent?"

Justice May delivered the opinion of the court, with all justices joining the unanimous decision. The court indicated it found the answer to the jurisdictional question in the text of the Iowa Code, emphasizing the legislature's chosen language as determinative.

The case represents a significant development in corporate law and jurisdiction issues affecting out-of-state businesses operating in Iowa. The ruling will have implications for how foreign corporations understand their legal exposure when they register to conduct business in Iowa and designate agents for service of process.

Certified questions arise when federal courts encounter unsettled state law issues that are central to resolving federal cases. Rather than making their own interpretation of state law, federal judges can certify these questions to state supreme courts, which are the ultimate authorities on their own state's laws.

The legal teams involved in the case included experienced attorneys from multiple states. Representing the CRST defendants were James A. Eckhart, Angela S. Cash, and James H. Hanson of Scopelitis, Garvin, Light, Hanson & Feary, P.C., based in Indianapolis, Indiana. Additional counsel included Thomas D. Wolle and Kevin J. Visser of Simmons, Perrine, Moyer, Bergman, PLC in Cedar Rapids.

For the plaintiff, Michael von Klemperer of Fegan Scott LLC in Washington, D.C., argued the case alongside J. Barton Goplerud and Brian O. Marty of Shindler, Anderson, Goplerud & Weese, P.C., in West Des Moines.

The State of Iowa participated as amicus curiae, represented by Attorney General Brenna Bird, Solicitor General Eric Wessan, and Assistant Solicitor General Ian M. Jongewaard.

The case was submitted to the Iowa Supreme Court on November 13, 2025, and decided approximately five weeks later on December 19, 2025, demonstrating the court's priority in resolving the certified question to allow the federal case to proceed.

Personal jurisdiction questions are fundamental to determining whether courts can exercise authority over out-of-state defendants. The traditional requirements include that defendants have sufficient minimum contacts with the forum state and that exercising jurisdiction would not offend traditional notions of fair play and substantial justice.

For foreign corporations, the act of registering to do business in a state often involves appointing an agent for service of process, which allows plaintiffs to serve legal documents on the company through the designated agent rather than attempting service at the company's home state.

The Iowa Supreme Court's answer to the certified question will now return to the federal district court, where Chief Judge Williams can apply the state law interpretation to resolve the jurisdictional challenge in the underlying class action lawsuit.

Class action lawsuits like *Kelchner* often involve complex procedural issues, particularly when they include defendants from multiple states. The resolution of jurisdictional questions early in litigation helps establish which courts can hear the case and which defendants must participate in the proceedings.

The unanimous nature of the Iowa Supreme Court's decision suggests the justices found the statutory language clear and unambiguous in addressing the jurisdictional question. This type of clarity in state law interpretation provides valuable guidance for both courts and practitioners handling similar jurisdictional challenges involving foreign corporations registered to do business in Iowa.

The ruling will likely influence how attorneys advise out-of-state corporations about their potential legal exposure when registering to conduct business in Iowa, and may affect litigation strategies in cases involving foreign corporate defendants operating in the state.

Topics

personal jurisdictionforeign corporation registrationservice of processclass actioncertified questioninterstate commerce

Original Source: courtlistener

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