IN THE IOWA DISTRICT COURT FOR [COUNTY] COUNTY

[PLAINTIFF FULL LEGAL NAME],
  Plaintiff,
  v.
[DEFENDANT FULL LEGAL NAME(S)],
  Defendant(s).

Case No.: [__]

PLAINTIFF’S ORIGINAL PETITION AT LAW AND JURY DEMAND

[// GUIDANCE: Iowa practice traditionally refers to the initiating pleading as a “Petition” rather than a “Complaint.”]

TABLE OF CONTENTS

I. Parties, Jurisdiction, and Venue
II. Statement of Facts
III. Causes of Action
 Count 1 – Premises-Liability Negligence
 [Optional] Count 2 – Negligence Per Se (Building/Code Violation)
IV. Damages
V. Comparative Fault Allegations
VI. Conditions Precedent & Notice
VII. Prayer for Relief
VIII. Demand for Jury Trial
IX. Reservation of Rights to Amend
X. Verification
XI. Certification of Service

I. PARTIES, JURISDICTION, AND VENUE

1. Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is an individual resident of [County], Iowa, and is of the age of majority.
2. Defendant(s). [DEFENDANT NAME(S)] (“Defendant”) is/are [an Iowa corporation / a foreign corporation authorized to do business in Iowa / an individual resident of ____ County, Iowa]. Service of process may be perfected upon Defendant at [registered agent / principal place of business / residence], [full address].
3. Jurisdiction. This Court has subject-matter jurisdiction over this action pursuant to Iowa law because the amount in controversy exceeds the jurisdictional minimum of this Court, exclusive of interest and costs, and because the acts and omissions complained of occurred in Iowa.
4. Venue. Venue is proper in this county because the cause of action arose here and/or Defendant’s principal place of business or residence is located here.

II. STATEMENT OF FACTS

5. On or about [DATE], Plaintiff lawfully entered Defendant’s premises located at [ADDRESS] (the “Premises”) as an [invitee/licensee].
6. At all relevant times, Defendant owned, controlled, occupied, and/or had responsibility for the maintenance of the Premises.
7. A dangerous condition existed on the Premises, specifically [describe hazard—e.g., an accumulation of water/slippery substance/unrepaired flooring, etc.], which was not open and obvious to Plaintiff.
8. Defendant knew or, in the exercise of reasonable care, should have known of the dangerous condition because [describe facts supporting actual or constructive notice—e.g., long-standing leak, prior complaints, employee observations, lack of inspections].
9. Defendant failed to warn of, remedy, or barricade the dangerous condition.
10. As Plaintiff traversed the Premises in a reasonably prudent manner, Plaintiff slipped/tripped, fell, and sustained severe bodily injuries, including but not limited to [list general injuries—e.g., fractures, soft-tissue injuries], along with related medical expenses, lost wages, pain, and mental anguish.
11. Defendant’s acts and omissions were a proximate and producing cause of Plaintiff’s injuries and damages.

III. CAUSES OF ACTION

Count 1 – Premises-Liability Negligence

12. Plaintiff realleges Paragraphs 1–11 as if fully set forth herein.
13. Defendant owed Plaintiff a duty of reasonable care to maintain the Premises in a condition that was reasonably safe, to inspect for hazards, and to warn of or remedy dangerous conditions.
14. Defendant breached that duty by:
     a. Failing to maintain the floor/walkway free from hazardous conditions;
     b. Failing to conduct reasonable inspections;
     c. Failing to provide warnings, signage, or barriers; and
     d. Such other negligent acts or omissions as discovery may reveal.
15. Defendant’s breach directly and proximately caused Plaintiff’s injuries and damages.

[Optional]

Count 2 – Negligence Per Se (Violation of Statute/Ordinance/Building Code)

16. Plaintiff realleges Paragraphs 1–15 as if fully set forth herein.
17. At the time of the incident, Defendant was subject to [identify specific ordinance/code].
18. Defendant violated said statute/ordinance, and Plaintiff is within the class of persons the statute/ordinance was designed to protect.
19. Defendant’s statutory violation constitutes negligence per se and proximately caused Plaintiff’s damages.

IV. DAMAGES

20. Pursuant to Iowa law, Plaintiff seeks recovery of all damages allowed, including but not limited to:
     a. Past and future medical expenses;
     b. Past and future physical pain and suffering;
     c. Past and future mental anguish;
     d. Past and future loss of earnings and impairment of earning capacity;
     e. Physical impairment and/or disfigurement;
     f. Loss of enjoyment of life;
     g. Pre-judgment and post-judgment interest as allowed by law; and
     h. Costs of suit and such other and further relief as the Court deems just and proper.
21. Plaintiff does not plead a specific dollar amount of unliquidated damages but pleads that the amount sought will exceed the jurisdictional minimum of this Court. [// GUIDANCE: Iowa practice prohibits stating a specific dollar amount for unliquidated damages in the Petition.]

V. COMPARATIVE FAULT ALLEGATIONS

22. In accordance with Iowa’s Comparative Fault Act, Iowa Code ch. 668, Plaintiff affirmatively pleads that Plaintiff’s fault, if any, was less than 50 percent of the total fault causing the injuries herein.
23. Plaintiff contends Defendant’s fault exceeds any fault that may be attributed to Plaintiff; however, Plaintiff pleads comparative fault to comply with statutory requirements and to avoid waiver.

VI. CONDITIONS PRECEDENT & NOTICE

24. All conditions precedent to the filing of this action have occurred, have been performed, or have been waived.
25. [If municipal defendant] Plaintiff provided timely notice pursuant to Iowa Code § 670.5 on [DATE].
26. [If no statutory notice required] No statutory pre-suit notice was required for the claims asserted herein.

VII. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays that Defendant be cited to appear and answer, and that upon final trial or hearing, the Court enter judgment in favor of Plaintiff and against Defendant for:
1. All categories of damages set forth above, in an amount to be determined by the trier of fact;
2. Pre- and post-judgment interest as allowed by law;
3. Costs of court; and
4. Such other and further relief, both at law and in equity, to which Plaintiff may show entitlement.

VIII. DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues so triable under the Constitution of the State of Iowa and applicable law.

IX. RESERVATION OF RIGHTS TO AMEND

Plaintiff reserves the right to amend this Petition to conform to evidence, to add additional parties, claims, or damages, and to seek punitive damages pursuant to Iowa Code ch. 668A, if supported by evidence developed in discovery.

X. VERIFICATION

[PLAINTIFF NAME], being first duly sworn, deposes and states that the factual allegations contained in this Petition are true and correct to the best of [his/her] knowledge, information, and belief.

[PLAINTIFF NAME]

State of Iowa )
County of [____] ) SS:

This instrument was acknowledged before me on [DATE] by [PLAINTIFF NAME].

Notary Public in and for the State of Iowa
My commission expires: _____
[// GUIDANCE: Omit the Verification if local practice does not require it or if Plaintiff prefers to provide it later.]

XI. CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of [MONTH], [YEAR], I electronically filed the foregoing document with the Clerk of Court using the Electronic Document Management System (EDMS), which will send notice of electronic filing to all counsel of record, and that I served a copy upon any self-represented party at the address listed in the court file.

[ATTORNEY NAME], #__
[LAW FIRM NAME]
[Street Address]
[City], Iowa [ZIP]
Telephone: ()-_
Email: [____]
ATTORNEY FOR PLAINTIFF
[// GUIDANCE: Include the attorney’s Iowa Bar number. Ensure EDMS registration prior to filing.]