Iowa Court Says No Contract Existed between Farmland Owner and Son

On August 17, 2022, the Iowa Court of Appeals affirmed that two sisters could not have interfered with their brother’s alleged contract with their parents to become the sole owner of an 80-acre parcel of farmland. The brother claimed to have an oral contract with their mother. Because the farmland was owned by the siblings’ father, the brother did not have a contract with the owner of the property.

Background

The plaintiff’s parents owned several parcels of farmland including an 80 acre parcel known as the “Stillwell Farm.” In his petition, the plaintiff claimed that he verbally contracted with his parents to work on the family farm in exchange for the Stillwell Farm. After the plaintiff’s mother passed away, his father transferred the Stillwell Farm into a trust. The trust named two of the plaintiff’s sisters as trustees. After his father passed away, the plaintiff learned that he would not receive the entire Stillwell Farm.

The plaintiff brought claims for intentional interference with an inheritance and intentional interference with a contract against two of his sisters. He alleged that they convinced their father to breach the contract. The district court found that the plaintiff’s lawsuit was precluded without a simultaneous will contest and granted each sisters’ motion for summary judgment. See Youngblut v. Youngblut, 945 N.W.2d 25, 35-37 (Iowa 2020). The plaintiff appealed the district court’s ruling on his claim for intentional interference with a contract only.

Intentional Interference with a Contract

On appeal, the Iowa Court of Appeals concluded that the plaintiff’s claim failed on its merits. To prove that intentional interference with a contract occurred, the proponent must show, among other things, that the plaintiff had a contract with a third-party. Green v. Racing Ass’n of Cent. Iowa, 713 N.W.2d 234, 243 (Iowa 2006).

Here, the court determined that the plaintiff did not have a contract with the owner of Stillwell Farm. The plaintiff testified that his mother promised to give him the farm. However, his mother never owned the farm; the farm was only in his father’s name. Therefore, the court found that the sisters could not have interfered with the contract by manipulating their father because no contract existed between the father and son.

Given the basis of its decision, the court did not need to determine whether Youngblut applies to claims for interference with a contract.