In 2003, a dispute developed between a farmer and a grain cooperative when the cooperative allegedly improperly applied herbicide to the farmer’s land. In 2008, the plaintiff farmer filed suit against the defendant cooperative, asking the trial court to award damages based upon the loss of yields he sustained. During the trial and throughout the suit, the plaintiff, unrepresented by legal counsel, was repeatedly admonished by the court to comply with the court’s rules of procedure.
During trial and in depositions, the plaintiff repeatedly answered questions at trial and in depositions by stating that he couldn’t answer questions because he didn’t have legal counsel to advise him. The plaintiff also accused the defendant’s attorney of conspiring against him and tampering with his witnesses. The trial court judge ultimately dismissed the case after concluding that the plaintiff filed pleadings that were “blatantly” in violation of the Iowa Rules of Civil Procedure (§1.413(1) “for the purpose of harassment and intimidation.” The court went on to state that while it “recognizes everyone’s right to due process, that right is conditioned upon the party’s willingness to comply with court rules.”
The plaintiff appealed and the Iowa Court of Appeals reinstated the case. According to the appellate court the trial court’s dismissal of the plaintiff’s suit under Iowa Rule of Civil Procedure 1.413(1) was not an independent basis for dismissal- meaning that failure to comply with this rule alone is not enough to throw out a plaintiff’s suit. Though the plaintiff repeatedly violated the rules and filed motions with an “improper purpose,” the trial court was not entitled to dismiss the suit entirely. Thus, the case was remanded for a trial on the merits. Buhr v. Howard County Equity, No. 1-084/10-0776 (Iowa Ct. App. Apr. 27, 2011).