The Iowa Court of Appeals selects certain opinions for publication in the Northwestern Reporter. In December, the Court of Appeals selected three opinions for publication. Following are summaries of those opinions.
Opinion date: Oct. 1, 2025
On appeal from Muscatine County District Court
Issue: Did the high bidder in an online farmland auction have a contract with the seller based on an email from the auctioneer informing him he had the highest bid?
After participating in an online auction for farmland, Stephen Dierickx received an email from DreamDirt Auctions that he had the high bid, congratulating him “on your auction purchase” and providing an invoice “for the items you won.” About two hours later, DreamDirt emailed again, saying the landowner rejected his offer and made a counteroffer at a higher price. Dierickx rejected the counteroffer and the land was sold to Vail Holdings.
Dierickx sued, claiming he had a valid contract to buy the farmland asserting claims of breach of contract, negligent misrepresentation, fraudulent misrepresentation, consumer fraud, slander of title, and quiet title. The Muscatine District Court dismissed all of his claims on summary judgment, which the Court of Appeals affirmed.
The case was heard by Court of Appeals Judges Julie Schumacher, Gina Badding and Samuel Langholz. The Court said the terms and conditions of the auction made clear that the seller reserved the right to accept or reject any and all bids and that being the highest bidder does not form a contract until the high bidder is notified that the seller has accepted it.
“An auctioneer has the right to set the terms for the auction—through ‘posted terms or conditions’ and any modifications or additions announced orally by the auctioneer ‘at the beginning of the sale’,” Court of Appeals Judge Langholz wrote for the Court, citing a 1909 decision of the Iowa Supreme Court. “And those terms and conditions bind bidders and purchasers in the auction whether they are aware of them or not.”
Iowa courts have long held that a bid by a potential purchaser in an auction is by default nothing more than an offer by one side that is not binding until it is accepted by the other side. More recently, a default auction is known as an auction “with reserve,” where the auctioneer may withdraw the goods offered at any time until completion of the sale has been announced.
But default rules can be modified by the terms and conditions of a particular auction where the default is reversed and property on auction becomes an offer to sell at any price and can be revoked only if no bid is received within a reasonable time. In what’s known as an absolute auction, the property goes to the bidder offering the highest price.
Based on the district court’s summary-judgment record, no term or condition governing the auction in this case modified the default rule that would transform it into an absolute auction without reserve, the Court of Appeals said, and no term limited the seller’s default right to withdraw its property from the auction during bidding.
DreamDirt’s email to Dierickx congratulating him on his “auction purchase” could be read as suggesting a contract had been formed, Court of Appeals Judge Langholz wrote, but it went on to say that 10% earnest funds were “due upon Seller’s acceptance of your bid,” and it reiterated that the sellers “reserve the right to take up to 4 hours after bidding ends to accept the final bid” and that being the high bidder “does not form a contract until the auctioneer announces the property sold and you are notified the seller has accepted your bid.”
“So at best, perhaps the email was the necessary announcement by DreamDirt that the property was sold,” he wrote. “But it was not the required notification that ‘the seller has accepted your bid.’ And so, by the express terms stated in the email and the governing common law, no contract to buy the land was formed between Dierickx and Gatzionis.”
John Reisdorf v. Emily Poling, No. 24 -1852
Opinion date: Oct. 1, 2025
On appeal from Scott County District Court
Issue: Did a grandfather fail to overcome the statutory presumption that the mother of his grandchildren properly denied him visitation rights?
Following the death of his biological son, John Reisdorf petitioned the Scott County District Court under Iowa Code Chapter 600C for visitation rights with his two grandchildren whose mother had cut off Reisdorf’s access. The district court denied his request and the Iowa Court of Appeals affirmed. The case was considered without oral argument by Chief Court of Appeals Judge Mary Tabor and Court of Appeals Judges Sharon Soorholtz Greer and Tyler Buller.
In the absence of grandparent visitation rights under common law, the Iowa Legislature enacted Chapter 600C that allows grandparents to petition for visitation of their grandchildren when the parent of the minor child, who is the child of the grandparent, is deceased. But the statute provides a rebuttable presumption that a parent’s decision to deny visitation to a grandparent is in the best interest of minor children.
To decide if that presumption has been rebutted, the district court is required to find that the grandparent proved with clear and convincing evidence that, among other things, the parent being asked to permit visitation is unfit to make the decision, and that “the relative benefit to the child of granting visitation greatly outweighs any effect on the parent-child relationship.”
Reisdorf made no mention at trial related to any of the elements of impairment outlined in the statute, and no one contested that [the childrens’ mother] was a “fit parent,” the Court of Appeals said. “Thus, because [Reisdorf] failed to rebut the presumption involving [the mother’s] decision, which was one of the three elements he had to address under the statute, we find the petition was appropriately dismissed.”
Opinion date: Aug. 6, 2025
On appeal from Cerro Gordo County District Court
Issue: Were the claims of the father of a child who died in his mother’s care correctly dismissed by the Cerro Gordo County District Court?
Two years after the death of his child due to malnutrition while in the child’s mother’s care, Scott R. Luke sued the state and several other defendants he alleged were connected with the child-in-need-of-assistance case involving the child, who had been removed from his custody. He asserted claims of wrongful death, loss of consortium, and federal civil rights violations.
The district court dismissed all of Luke’s claims, finding that because he was not the administrator of his son’s estate he could not bring a wrongful-death claim; that he failed to exhaust his tort claim against the State; that the statute of limitations barred his loss-of-consortium and federal civil rights claims against all defendants; and that Families First and its employee were not state actors and thus could not be sued under Section 1983 of the U.S. Code.
The Court of Appeals affirmed the district court. The case was considered without oral argument by Chief Court of Appeals Judge Mary Tabor and Court of Appeals Judges Paul Ahlers and Samuel Langholz.
In addition to agreeing with the district court on its dismissal of each of Luke’s claims, the Court of Appeals added a note regarding a “preliminary concern” with Luke’s appeal:
“Luke is self-represented, and we will consider his arguments as we understand them and to the extent they are preserved for appeal,” Court of Appeals Judge Langholz wrote in the panel opinion. “But we also note that Luke’s brief is riddled with citations to nonexistent Iowa cases. We share the appellees’ concerns that Luke possibly misused an artificial intelligence tool when preparing his brief, resulting in pages of discussion based on fake cases. And we stress that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.”
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