IN THE IOWA DISTRICT COURT FOR [__] COUNTY

[PLAINTIFF FULL LEGAL NAME],
  Plaintiff,
v.
[DEFENDANT FULL LEGAL NAME],
  Defendant.

Case No. [____]

MOTION FOR SUMMARY JUDGMENT

[// GUIDANCE: Ensure the caption conforms to Iowa R. Civ. P. 1.421 and any local formatting requirements. Align party designation (Plaintiff/Defendant) with the operative pleadings.]

TABLE OF CONTENTS

1. Introduction .............................................................................................. 1
2. Statement of Undisputed Material Facts ................................................ 1
3. Summary-Judgment Standard ................................................................ 3
4. Argument .................................................................................................... 4
5. Request for Oral Argument and Hearing Date .................................... 7
6. Conclusion & Prayer for Relief ............................................................. 7
7. Certification of Compliance with Brief-Length Limits ....................... 8
8. Certificate of Service ................................................................................. 9
9. Proposed Order (attached) ....................................................................... 10

[// GUIDANCE: Auto-generate page numbers after finalization.]

TABLE OF AUTHORITIES

Rules
Iowa R. Civ. P. 1.981 ..................................................................................... 3, 4

[// GUIDANCE: Cite ONLY rules/ statutes you are 100 % certain about. Omit case law per Citation Policy.]

1. INTRODUCTION

Pursuant to Iowa Rule of Civil Procedure 1.981, Defendant [DEFENDANT] respectfully moves for summary judgment on all claims asserted by Plaintiff [PLAINTIFF]. The undisputed record demonstrates that no genuine issue of material fact exists and that Defendant is entitled to judgment as a matter of law.

2. STATEMENT OF UNDISPUTED MATERIAL FACTS

Defendant submits the following numbered facts, each supported by specific record citations as required by Iowa R. Civ. P. 1.981(4):

1. On [DATE], Plaintiff and Defendant executed the [RELEVANT AGREEMENT] (the “Agreement”). See Affidavit of [NAME] ¶ 3 & Ex. A (“Agreement”).
2. The Agreement obligated Defendant to [BRIEFLY DESCRIBE OBLIGATION]. Id. § [__].
3. Plaintiff failed to perform the following conditions precedent: [DESCRIPTION]. See Dep. of [NAME] 45:3-46:12 (“[QUOTE]”).
4. …

[// GUIDANCE: Provide a separate “Defendant’s Statement of Undisputed Material Facts” as an exhibit if local practice requires. Cross-reference exhibit numbers consistently.]

3. SUMMARY-JUDGMENT STANDARD

Under Iowa R. Civ. P. 1.981(3), summary judgment “shall be rendered forthwith” if the pleadings, depositions, answers to interrogatories, admissions, and affidavits show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.

The movant bears the initial burden of identifying portions of the record demonstrating the absence of a genuine dispute. Iowa R. Civ. P. 1.981(5). Once met, the non-movant must set forth specific facts—by affidavit or otherwise—that show a genuine issue exists for trial. Id.

4. ARGUMENT

[// GUIDANCE: Break this section into discrete legal issues/elements. Each subsection should (1) cite the controlling rule or statutory provision, (2) apply the undisputed facts, and (3) reach a clear conclusion.]

4.1 Claim One: [Insert Claim Title]

4.1.1 Element One—[NAME OF ELEMENT]
• Undisputed Fact ¶ [__] establishes [POINT].
• Iowa R. Civ. P. 1.981(3) allows judgment where, as here, no factual dispute exists.
• Therefore, Defendant satisfies Element One as a matter of law.

4.1.2 Element Two—[NAME OF ELEMENT]
• …

4.1.3 Conclusion as to Claim One
Because Plaintiff cannot establish the essential elements of [CLAIM], Defendant is entitled to judgment on Count I.

4.2 Claim Two: [Insert Claim Title]

(Repeat structured analysis.)

5. REQUEST FOR ORAL ARGUMENT AND HEARING DATE

Pursuant to Iowa R. Civ. P. 1.431(2)(e), Defendant requests oral argument and proposes the motion be heard on [DATE], or as soon thereafter as the Court’s docket permits.

6. CONCLUSION & PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:

1. Grant this Motion for Summary Judgment;
2. Enter judgment in favor of Defendant on all counts in Plaintiff’s [Operative Petition/Complaint];
3. Tax costs to Plaintiff pursuant to Iowa R. Civ. P. 1.413; and
4. Grant such further relief as the Court deems just and proper.

7. CERTIFICATION OF COMPLIANCE WITH BRIEF-LENGTH LIMITS

I certify that this brief complies with [LOCAL RULE OR ORDER] limiting principal briefs to [__] pages/words. This document contains [___] pages (excluding caption, tables, certificates, and signature block) as counted by the word-processing system used to generate it.

8. CERTIFICATE OF SERVICE

I hereby certify that on [DATE], I filed the foregoing Motion for Summary Judgment via the Iowa Electronic Document Management System, which will send notice of electronic filing to all registered counsel of record.

/ s/ [ATTORNEY NAME]
[ATTORNEY NAME] (AT #[______])
[LAW FIRM NAME]
[Address] • [Phone] • [Email]
Counsel for Defendant

9. PROPOSED ORDER

(Submit as a separate attachment, per Iowa R. Civ. P. 1.981(6). Sample language provided below for convenience.)

text
IN THE IOWA DISTRICT COURT FOR [__] COUNTY
[CAPTION]

PROPOSED ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

The Court, having considered Defendant’s Motion for Summary Judgment, the Statement of Undisputed Material Facts, all supporting documents, and applicable law, finds that there is no genuine issue of material fact and that Defendant is entitled to judgment as a matter of law under Iowa R. Civ. P. 1.981.

IT IS THEREFORE ORDERED:
1. Defendant’s Motion for Summary Judgment is GRANTED.
2. Judgment is entered in favor of Defendant and against Plaintiff on all claims.
3. Costs are taxed to Plaintiff pursuant to Iowa R. Civ. P. 1.413.
4. The Clerk shall close the case.

SO ORDERED this ___ day of ____, 20__.

Judge, Iowa District Court

[// GUIDANCE:
• Attach all cited evidence as sequentially labeled exhibits (Ex. A, B, C).
• Ensure affidavits satisfy Iowa R. Civ. P. 1.981(5) (made on personal knowledge, setting forth admissible facts, showing competence of affiant).
• If relying on electronic records, authenticate under Iowa R. Evid. 5.902 or include foundation testimony.
• Confirm local briefing deadlines (often 15 days before hearing for resistance, 7 days for reply) and insert procedural calendar placeholders.
• Some Iowa judicial districts impose page limits (e.g., 25 pages) via administrative orders—verify and update Section 7 accordingly.]

END OF DOCUMENT