Statute Annotations › Iowa › Iowa Code § 614.1

Iowa Code § 614.1

Limitations of actions: the cases that interpreted this section

Jurisdiction
Iowa
Case notes
306
Cited in passing
123
Citing cases indexed
422
Case dates
1966–2026
Screened through
2026-05-29
Checked for later law changes
2026-10-03
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No reviewed case has held this section invalid, preempted, superseded or repealed.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.

429 citing cases reviewed: 306 interpreted the section (annotated below), 123 cited it only in passing. Cases filed after 2026-05-29 may not have been reviewed yet.

Have a situation under Iowa Code § 614.1?

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

Municipal ordinance penalties and collection

Section 614.1(1)'s one-year limit applies only to judicial proceedings to enforce payment of an ordinance penalty, not to out-of-court collection efforts.

James A. Stogdill, Christopher Determan, Mathew D. Johnson, Alesha Smith And Kirk E. Yentes v. City of Windsor Heights, · filed 2023-06-09(1)

The statute of limitations is wholly inapplicable to the city’s out-of-court collection efforts. ... The statute then goes on to provide that those actions “to enforce the payment of a penalty or forfeiture under an ordinance” must be brought “within one year.” Id. § 614.1(1). As the text indicates, the statute of limitations applies only to “[a]ctions.” Id. § 614.1; ... In this context, an “action” denotes a “judicial proceeding.” Action, Black’s Law Dictionary (11th ed. 2019).
Read the full opinion on CourtListener →

Section 614.1(1) does not apply to out-of-court collection efforts for municipal-infraction penalties; it governs actions brought in court within one year.

Francis Livingood, Christoper Maury, and Daniel Robbins v. City of Des Moines, Iowa · filed 2023-06-09(1)

For the reasons explained in Stogdill v. City of Windsor Heights, ___ N.W.2d ___, ___ (Iowa 2023), filed today, the statute of limitations is inapplicable to the city’s use of the income offset program because the statute of limitations does not apply to collection efforts made outside of court proceedings.
Read the full opinion on CourtListener →

Iowa Code § 614.1(2) supplies a two-year statute of limitations for § 1983 actions in Iowa.

Valdivia · filed 2026-02-11(2)

Section 1983 claims are governed by the relevant state’s personal injury statute of limitations. Wycoff v. Menke, 773 F.2d 983, 984 (8th Cir. 1985). In Iowa, § 1983 actions are subject to a two-year statute-of-limitations. See Iowa Code § 614.1(2).
Read the full opinion on CourtListener →

Two-year § 1983 limitations

Iowa Code § 614.1(2) imposes a two-year limitations period on § 1983 actions in Iowa.

Lillie v. Cord · filed 2022-05-18(2)

Moreover, the complaint is time-barred because it was filed more two years after the April 10, 2020 hearing about which Lillie complains. Section 1983 claims are governed by the relevant state’s personal injury statute of limitations. ... In Iowa, § 1983 actions are subject to a two-year statute-of-limitations. See Iowa Code § 614.1(2).
Read the full opinion on CourtListener →

Iowa Code § 614.1(2) gives § 1983 actions a two-year statute of limitations because they are governed by Iowa’s personal-injury limitations period.

Lillie v. United States Postal Service · filed 2022-05-18(2)

Section 1983 claims are governed by the relevant state’s personal injury statute of limitations. Wycoff v. Menke, 773 F.2d 983, 984 (8th Cir. 1985). In Iowa, § 1983 actions are subject to a two-year statute-of-limitations. See Iowa Code § 614.1(2).
Read the full opinion on CourtListener →

Section 614.1(2) supplies a two-year limitations period for § 1983 claims arising in Iowa.

Rondoe Reece Wright v. Loeffelholz · filed 2003-10-07(2)

Upon careful review of the record, we conclude dismissal was proper because Wright’s claims, which accrued at least four years prior to initiation of this action, were barred by the applicable statute of ... limitations. See Iowa Code § 614.1(2) (West Supp. 2003) (limitations period for personal injury actions is two years after accrual); Wilson v. Garcia, 471 U.S. 261, 279–80 (1985).
Read the full opinion on CourtListener →

Notes 301–306 of 306, oldest cases first.

Which of these rulings fit your facts?

Describe your situation under Iowa Code § 614.1. Ezel checks it against the cases on this page and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace