Statute Annotations › Iowa › Iowa Code § 602.6101

Iowa Code § 602.6101

Jurisdiction and venue of district courts: the cases that interpreted this section

Jurisdiction
Iowa
Case notes
23
Cited in passing
34
Citing cases indexed
58
Case dates
1986–2025
Screened through
2025-05-23
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

57 citing cases reviewed of 58 in the citation index: 23 interpreted the section (annotated below), 34 cited it only in passing. Cases filed after 2025-05-23 may not have been reviewed yet.

Have a situation under Iowa Code § 602.6101?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

District court jurisdiction

Section 602.6101 gives Iowa district courts statewide jurisdiction, so improper venue does not deprive a district court of authority to rule.

Petty v. Kouris · filed 2023-03-29

There is “nothing in this statute to indicate that Iowa’s district courts hold less than statewide jurisdiction over all appropriate matters. Venue is a matter of proper situs, not jurisdiction.” In re Marriage of Rathe, 521 N.W.2d 748, 749 (Iowa 1994). The district court had jurisdiction and authority to rule on the motion to dismiss.
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Section 602.6101’s grant of general district court jurisdiction extends to probate matters, including applications to authorize sterilization of a mentally incapacitated ward.

Matter of Guardianship of Matejski · filed 1988-02-17

We think this finding of plenary jurisdiction also follows from the statutory consolidation of jurisdiction over all probate actions, Iowa Code 602.-6101 (1985), and our canon of construction which gives statutory language its ordinary meaning unless a contrary meaning is suggested by the legislature, e.g., Good v. Iowa Civil Rights Comm’n, 368 N.W.2d 151, 155 (Iowa 1985). ... We conclude that our district courts possess subject matter jurisdiction over, and accordingly may hear and determine, applications seeking authorization for sterilization of a mentally incapacitated ward, such as that involved here.
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Section 602.6101 gives district courts exclusive, general, and original jurisdiction over all civil, criminal, probate, and juvenile actions, proceedings, and remedies.

McCarthy v. Iowa District Court for Jefferson County · filed 1986-02-13

The district court has exclusive, general, and original jurisdiction of all actions, proceedings and remedies, civil, criminal, probate, and juvenile. Iowa Code § 602.6101. District courts have the authority to enter consent judgments.
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Section 602.6101 establishes that Iowa district courts have general and unlimited jurisdiction.

Swanson v. Best Buy Co., Inc. · filed 1990-02-28

The Iowa District Court is a court of general and unlimited jurisdiction, Iowa Code § 602.6101, and is competent to adjudicate FLSA claims.
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Section 602.6101 establishes Iowa's unified trial court, so Iowa district courts have statewide jurisdiction over appropriate matters.

In Re the Marriage of Rathe · filed 1994-09-21

Iowa has a unified trial court. Iowa Code § 602.6101 (1993). We read nothing in this statute to indicate that Iowa’s district courts hold less than statewide jurisdiction over all appropriate matters.
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Section 602.6101 gives the district court general original jurisdiction, but allows concurrent jurisdiction in another tribunal, so an administrative hearing before district-court proceedings does not unlawfully remove the district court’s jurisdiction.

Hughes v. City of Cedar Rapids · filed 2015-07-02

Contrary to Plaintiffs’ assertion, the ATE system does not “tak[e] jurisdiction for traffic enforcement matters away from the Iowa District Court.” ... Rather, the ATE system allows a person who receives a Notice-of-Violation an opportunity to first object to the alleged violation at a City-sanctioned administrative hearing before proceeding to the Iowa district courts. Such a system amounts to, at most, concurrent jurisdiction over alleged municipal violations. ... Accordingly, the court shall dismiss Plaintiffs’ claims under Article V, sections 5 and 8 of the Iowa Constitution and under Iowa Code section 602.6101.
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Section 602.6101 grants the district court exclusive, general, and original jurisdiction over criminal proceedings, and a defendant’s mental health status does not affect that subject matter jurisdiction.

State of Iowa v. Young · filed 2016-07-27

Jurisdiction is granted by the state constitution and the state’s laws, and the district court “has exclusive, general, and original jurisdiction of all actions, proceedings, and remedies, civil, criminal, probate, and juvenile.” Iowa Code § 602.6101. Young’s case was a criminal proceeding, and as such, the district court had exclusive, general, and original jurisdiction over the matter. A defendant’s mental health status has no effect on the court’s subject matter jurisdiction.
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Section 602.6101 gives Iowa district courts exclusive, general, and original jurisdiction over all actions unless jurisdiction is conferred on another court, tribunal, or administrative body.

Hughes v. City of Cedar Rapids · filed 2016-11-02

Section 602.6101 establishes the jurisdiction of the Iowa District Court as “exclusive, general, and original jurisdiction of all actions . . . except in cases where exclusive or concurrent jurisdiction is conferred upon some other court, tribunal, or administrative body.” The drivers’ argument fails for the same reason as their claim for unjust enrichment; there is no improper delegation (or in statutory terms, conferral) of power upon Gatso.
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Section 602.6101 gives the district court exclusive, general, and original jurisdiction over involuntary-commitment proceedings; venue rules regulate how that jurisdiction is exercised rather than limiting subject-matter jurisdiction.

In the Matter of M.A., Alleged to Be Seriously Mentally Impaired, M.A. · filed 2017-03-22

Based on the legal principles set forth above, an involuntary-commitment proceeding is within the classification of cases identified in the Iowa Code as within the “exclusive, general and original jurisdiction” of the district court. Iowa Code § 602.6101. The directive of section 229.6 to file the action where the respondent is located or resides is a legislative “regulation[] for the manner in which jurisdiction is [to be] exercised,” Schott, 744 N.W.2d at 88 (citation omitted), but is not a limitation on subject matter jurisdiction.
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Section 602.6101 gives the district court generally exclusive jurisdiction over all actions, proceedings, and remedies, subject to an exception when another court, tribunal, or administrative body has exclusive or concurrent jurisdiction.

Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. C · filed 2019-01-25

Iowa Code section 602.6101 relates to the jurisdiction of the district court, which is generally exclusive, subject to certain exceptions. This provision states, in relevant part, ... The district court has exclusive, general, and original jurisdiction of all actions, proceedings, and remedies, civil, criminal, probate, and juvenile, except in cases where exclusive or concurrent jurisdiction is conferred upon some other court, tribunal, or administrative body.
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Section 602.6101 gives the district court all power usually possessed and exercised by trial courts of general jurisdiction.

Jefferie Scott Gray, Janice Gray, an J.G., as Successors in Interest to James Lee Hohenshell v. Michael B. Oliver, Olive · filed 2020-05-22

The Iowa Code provides, “The district court has all the power usually possessed and exercised by trial courts of general jurisdiction . . . .” Iowa Code § 602.6101 (2018). Determining the merits or demerits of a common law issue based on considerations of public policy is a question of law within the constitutional and statutory power of the district court.
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Section 602.6101 gives Iowa district courts exclusive, general, and original jurisdiction over civil, criminal, probate, and juvenile actions, proceedings, and remedies.

Smith v. Iowa Association of Community College Trustees · filed 2024-02-07

The district court is a court of general jurisdiction, and “[i]t is empowered by the Iowa Constitution to hear all cases in law and equity.” Shott v. Shott, 744 N.W.2d 85, 87 (Iowa 2008); see also Iowa Const. art. V, § 6 (“The district court shall be a court of law and equity, which shall be distinct and separate jurisdictions, and have jurisdiction in civil and criminal matters arising in their respective districts, in such manner as shall be prescribed by law.”); Iowa Code § 602.6101 (“The district court has exclusive, general, and original jurisdiction of all actions, proceedings, and remedies, civil, criminal, probate, and juvenile . . . .”). It is clear the court had subject matter jurisdiction over this case.
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Section 602.6101 gives Iowa district courts exclusive, general, and original jurisdiction over civil actions, proceedings, and remedies, including equitable suits.

Scheckel v. City of Oelwein and Fayette County Treasurer · filed 2024-07-03

With exceptions not relevant here, the Iowa Code likewise gives the district court “exclusive, general, and original jurisdiction of all [civil] actions, proceedings, and remedies.” Iowa Code § 602.6101. The district court thus had jurisdiction over Scheckel’s suit in equity.
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Section 602.6101 establishes the district court as Iowa’s single court of original jurisdiction, operating through separate case dockets.

Woodbury County Attorney v. Iowa District Court for Woodbury County · filed 1989-11-22

Iowa has only one court of original jurisdiction, the district court. Iowa Code § 602.6101. However, the district court has separate dockets for civil, criminal, juvenile, probate, small claims, and simple misdemeanor cases.
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Section 602.6101 leaves district courts without subject matter jurisdiction when the legislature assigns original jurisdiction over a claim to an administrative body.

Nedzad Mehmedovic as the Administrator of the Estate of Hus Hari Buljic and as the Administrator of the Estate of Sedika · filed 2025-05-23

Where the legislature by statute confers original jurisdiction not with the district court but “upon some other . . . administrative body”—as it has with the IWCA—we lack subject matter jurisdiction.
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Section 602.6101 does not preempt a city ordinance that offers an optional administrative hearing while preserving access to district court.

Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson and Geoff Tate Smith v. City of Cedar Rapids, Iowa and Gatso USA, Inc. · filed 2017-02-22

The plaintiffs also argue the process established by the ordinance unlawfully grants jurisdiction to an administrative board or hearing officer and is preempted by Iowa Code sections 602.6101 and 364.22(4), (6). ... With the persuasive federal decisions in mind, along with our own supreme court’s ruling, we conclude the district court correctly rejected the plaintiffs’ preemption argument.
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Subject matter jurisdiction

Section 602.6101 gives Iowa's unified district court exclusive, general, and original jurisdiction over civil and criminal actions unless another court or tribunal has exclusive or concurrent jurisdiction.

Michael Young, Applicant-Appellant v. State of Iowa · filed 2015-02-11

Iowa has a unified trial court denominated “The Iowa District Court.” Iowa Code § 602.6101. “The district court has exclusive, general, and original jurisdiction of all actions, proceedings, and remedies, civil, criminal . . . except in cases where exclusive or concurrent jurisdiction is conferred upon some other court, tribunal, or administrative body.” Iowa Code § 602.6101. ... In the absence of such proof, the State was free to enforce its criminal law against Young, and the district court had concomitant subject matter jurisdiction over the criminal proceeding.
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Section 602.6101 gives Iowa district courts subject matter jurisdiction over criminal cases.

Anthony Brown, Applicant-Appellant v. State of Iowa · filed 2014-07-16

The district court that tried the underlying case had subject matter jurisdiction over the criminal case. See Iowa Const. art. V, § 6.2; Iowa Code § 602.6101.
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Section 602.6101 gives district courts subject matter jurisdiction over civil actions.

The Estate of Lewis v. Looney · filed 2023-11-21

But the district court clearly had subject matter jurisdiction of this civil action as provided by Iowa Code section 602.6101.
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Concurrent jurisdiction

Section 602.6101 permits concurrent jurisdiction over municipal infractions by an administrative body and the Iowa District Court.

Brooks v. City of Des Moines · filed 2016-11-02

Section 602.6101 establishes the jurisdiction of the Iowa District Court as “exclusive, general, and original jurisdiction of all actions . . . except in cases where exclusive or concurrent jurisdiction is conferred upon some other court, tribunal, or administrative body.” ... Here, the home rule power and section 364.22(2) allow the City to create municipal infractions, and section 602.6101 allows for concurrent jurisdiction. The administrative body has concurrent jurisdiction with the Iowa District Court over ATE infractions. ... Since concurrent jurisdiction for municipal infractions is not irreconcilable with Iowa state law, the drivers fail to state a claim for a violation of section 602.6101.
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Section 602.6101 permits concurrent jurisdiction over municipal infractions, so an administrative body may share jurisdiction with the Iowa District Court over ATE infractions.

Brooks v. City of Des Moines · filed 2016-12-01

Section 602.6101 establishes the jurisdiction of the Iowa District Court as “exclusive, general, and original jurisdiction of all actions . . . except in cases where exclusive or concurrent jurisdiction is conferred upon some other court, tribunal, or administrative body.” ... Here, the home rule power and section 364.22(2) allow the City to create municipal infractions, and section 602.6101 allows for concurrent jurisdiction. The administrative body has concurrent jurisdiction with the Iowa District Court over ATE infractions. ... Since concurrent jurisdiction for municipal infractions is not irreconcilable with Iowa state law, the drivers fail to state a claim for a violation of section 602.6101.
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What counts as a court of record

Section 602.6101 establishes a unified Iowa District Court with general trial-court authority, and its small-claims docket is part of that court of record.

Liberty Credit Services Inc. v. Inlow · filed 2024-07-03

Below, Inlow admitted the 2002 judgment was issued by the “Iowa District Court.” So under the plain language of Iowa Code section 602.6101, the judgment was issued by a “court of record” and the twenty-year limitations period applies. See Iowa Code §§ 602.6101, 614.1(6).
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Section 602.6101 establishes Iowa's unified trial court as the district court.

S.S. v. Iowa District Court for Black Hawk County · filed 1995-02-22

Iowa Code section 602.6101 provides for a unified trial court — the district court.
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34 more cases cited this section only in passing

These cases mention the section without interpreting it (a string cite, a footnote, background). Listed so you can see the full citation record, not just the annotated rulings.

Rerat Law Firm v. Iowa District Court for Pottawattamie County, the court cites § 602.6101 only as support for the general proposition that the district court could hear a properly filed contract action. It does not interpret or apply the statute; the holding concerns the improper procedure used to assert the fee claim against nonparties. opinion →
Tyrrell v. Iowa District Court, the court uses § 602.6101 only to describe the unified trial-court structure as background for analyzing the appeal route; it does not interpret, apply, or decide any requirement of § 602.6101. opinion →
State v. Garr, the statute appears only in a footnote explaining the terminology and structure of Iowa's unified trial court; the court does not interpret, apply, or decide any issue about § 602.6101. opinion →
State v. Moret, section 602.6101 is cited only for the general proposition that Iowa has a unified district court. The court's actual holding concerns a district associate judge's authority under Iowa Code § 602.6306, not the meaning or application of § 602.6101. opinion →
Halverson v. Iowa District Court for Decatur County, the opinion quotes § 602.6101 only while describing the attorney's argument about the district court's jurisdiction. The court resolved the jurisdictional issue under Iowa Rule of Civil Procedure 236 and did not construe or apply § 602.6101. opinion →
Iowa Supreme Court Commission on Unauthorized Practice of Law v. A-1 Associates, Ltd., the court cited § 602.6101 to describe the unified district-court structure while deciding the scope of the separate statute governing the supreme court’s authority to admit persons to practice law, § 602.10101. It did not independently construe or apply § 602.6101. opinion →
EFCO Corp. v. Iowa Ass'n of Business and Industry, the statute is mentioned only while recounting EFCO’s argument in support of remand. The court analyzes federal removal and ERISA jurisdiction and does not construe or apply Iowa Code § 602.6101. opinion →
State v. Erdman, the court cites § 602.6101 only as background for the district court's general jurisdiction. Its actual jurisdictional holding concerns the $10,000 limitation in § 602.6306(2), so it does not decide what § 602.6101 means or how it applies. opinion →
State Of Iowa Vs. Khrista Kay Erdman, Always Affordable Bail Bonds, Inc. And Ranger Insurance, the court cites § 602.6101 only in a general statement about the source and scope of district-court subject matter jurisdiction. It does not construe or apply that statute; the actual ruling limits the district associate court’s jurisdiction under Iowa Code § 602.6306(2). opinion →
Reis v. Iowa District Court for Polk County, the statute is cited only in a footnote as support for the general proposition that Iowa courts have general jurisdiction. The opinion does not construe or apply § 602.6101; its jurisdictional analysis concerns enforcement of protective orders and unentered settlement agreements. opinion →
Jan Reis And Dean Stowers, Vs. Iowa District Court For Polk County, the court cites § 602.6101 only in a footnote for the background proposition that Iowa courts have general jurisdiction. It does not construe the statute or decide how it applies; the holding concerns jurisdiction to enforce a protective order and an unentered settlement agreement. opinion →
State v. Bartley, the court merely recited § 602.6101’s general jurisdiction of the unified district court. Its actual holding interpreted § 602.6306(2) and the authority of district associate judges to sentence class D felonies, not § 602.6101. opinion →
Misty S. Davis, as Mother and Next Friend of Brady Clifford v. Nicole Banley, and Robert B. Deck, Intervenor-Appellant., the court cites § 602.6101 in its scope-and-standard-of-review discussion as general support for a jurisdictional proposition, but does not construe the statute or decide what it requires or how it applies. opinion →
State of Iowa v. Scheckel, the court merely cited § 602.6101 as one authority for the general proposition that Iowa district courts have subject matter jurisdiction over criminal cases; it did not construe or analyze the statute. opinion →
First Bank of Nebraska v. AJR Peakview, Inc., the court cited § 602.6101 for the general jurisdiction of Iowa district courts, but did not interpret or otherwise decide what the statute means or requires. The statute was incidental to the court’s conclusion that the district court had subject-matter jurisdiction over the foreclosure action. opinion →
Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. C, the opinion quotes and briefly describes the statute in its overview of the relevant law, and reports plaintiffs’ argument that the administrative process conflicted with it. The available text does not show the court deciding what § 602.6101 requires or applying it to resolve the case. opinion →
Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. C, section 602.6101 is quoted and described in the background, and its application is presented as the plaintiffs’ preemption argument. The available opinion text does not show the court adopting or resolving that interpretation. opinion →
In the Matter of the Teresa Kasparbauer Revocable Living Trust, the court cited § 602.6101 while reciting the general subject-matter-jurisdiction rule in response to an unsupported jurisdictional argument, then expressly declined to consider the argument further. It did not interpret or apply the statute. opinion →
Richards v. Iowa District Court for Monona County, the statute is cited in a footnote to explain Iowa’s unified trial-court structure and why the county courts are technically the same court. The court does not decide a dispute about the statute’s meaning, requirements, coverage, or application; its holding concerns the improper declaratory-judgment respondent and the appropriate procedural vehicle. opinion →
Witham v. Employment Appeal Board, the court cites § 602.6101 only in a footnote to clarify that “district court” in the Iowa appeal provision means the Iowa state district court, not the federal district court. It does not interpret or apply § 602.6101. opinion →
Knutson v. Oellrich, the court cited § 602.6101 only to identify the establishment of Iowa's unified trial court system while considering whether older venue-authority precedent had been abrogated. It did not construe or apply the statute; the holding concerned the district court's authority after venue was transferred, based on precedent. opinion →
In re Marriage of Frazier, the statute is cited only in the dissent to support an argument about the district court’s inherent equitable authority; the majority did not adopt or construe that proposition. opinion →
In re Marriage of Frazier, the statute is cited only in the dissent as support for its view that the district court has inherent equitable authority; the majority does not adopt that interpretation or decide the case under § 602.6101. opinion →
State v. Davis, the court cited § 602.6101 only to identify the district court’s subject-matter jurisdiction. It did not interpret or decide the statute’s meaning, scope, or application; the decision concerned waiver of an objection to the amended trial information. opinion →
State v. Bradley, the court cited § 602.6101 only to support the unelaborated proposition that Iowa initially had subject matter jurisdiction; it did not interpret or apply the statute's terms. The jurisdiction issue was resolved instead under the dual-sovereignty doctrine and the effect of Missouri's prosecution. opinion →
Schott v. Schott, the court cited § 602.6101 in describing the district court's general jurisdiction, but did not interpret or apply the statute; the decision concerned the court's subject-matter jurisdiction and collateral attack on adoption decrees. opinion →
Schott Vs. Schott, the court cited section 602.6101 only as background support for the district court’s general jurisdiction; it did not construe or apply the statute, and its holding concerned the impermissibility of collaterally attacking the adoption decrees. opinion →
In Re the Marriage of Russell, the court cites the section as the source of the district court’s general jurisdiction while deciding whether common-law procedures could invoke that jurisdiction to modify a foreign support order. opinion →
Cincinnati Insurance Companies v. Kirk, the court cites the section for the district courts’ general jurisdiction while deciding whether the Workers’ Compensation Act gives the commissioner exclusive jurisdiction over the insurer’s fraud claims. opinion →
Cedar Rapids v. Marla Marie Leaf, the court cites the section in describing Leaf’s preemption argument and rulings by other courts, without stating its own rule for the section. opinion →
Reuven Weizberg, David Peter Veng-Pedersen, Jacob Patrick Dagel v. City of Des Moines, Iowa, and Gatso USA, Inc., the opinion reports the district court's dismissal of a claim based on the section but does not decide that claim. opinion →
City of Cedar Rapids v. Marla Marie Leaf, the court cited the section among the procedures Leaf received and rejected her challenge for lack of prejudice without deciding the section’s jurisdictional rules. opinion →
Jaks Properties, LLC v. St. Croix Hospice, LLC, the court cites the section as the basis for the district court’s jurisdiction over a section 626.33 claim. opinion →
State of Iowa v. Paul John Joseph Kramer, the court cites the section while recounting Kramer’s jurisdiction argument, then decides his competency, self-representation, and sentencing claims. opinion →

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