Rains v. Grieve, 808 N.W.2d 754 (Iowa Ct. App. 2011)

(plaintiff's spouse died in Florida in 2001 leaving most of estate to others via "payable on death" designations; plaintiff elected to take elective share and Florida court determined that elective share was at least $145,037 and named persons responsible for contributing to elective share, including defendant; defendant put POD assets into two accounts with total value of over $180,000; plaintiff filed action against defendant to enforce judgment against defendant and also claimed that defendant fraudulently made distributions from the two accounts with intent to avoid plaintiff as creditor; litigation settled with defendant agreeing to pay plaintiff $12,000 plus balance in account, but defendant sued account holder for placing hold on account for over a year which caused defendant to suffer loss because accounts dropped in value during 2008; court ruled that defendant failed to offer evidence he was damaged by failing withdrawing funds before decline in value; trial court decision affirmed - defendant's claim speculation).