Lowa cornfields at harvest time. Image credits: Wikimedia Commons
In 2024, the Iowa Court of Appeals decided Natvig v. 23-1992, filed on 30 October 2024, the court affirmed the dismissal of a challenge to Michael Natvig’s ownership of farmland that his father, Godfrey Natvig, had transferred to him, holding that Michael had rebutted the presumption of undue influence. In 1994, Godfrey and Theodora conveyed 40 acres to Michael. After Theodora died in 2002, Godfrey conveyed another 40 acres to Michael while keeping a life estate, which let him keep the right to use the land during his lifetime. Godfrey’s will, made in 2004, divided his estate equally among his eight children but gave Michael an option to buy the remaining 80 acres of farmland if the other heirs wanted to sell. In a codicil dated 20 May 2016, Godfrey wrote that he wanted the real estate to stay in the family. The codicil said the last 80-acre tract had been conveyed to Michael in return for services he had rendered, was rendering and would render in the future, and it left all real estate to Michael. They argued that Godfrey wrongly believed his children planned to sell the 80 acres after his death. It noted that the final 80 acres were part of a pattern of earlier transfers to Michael and that opportunity alone was not enough to support an inference of undue influence.
Family farms can represent more than a source of income. For some families, they carry a history of work, memories and dedication to keeping the land together. Yet succession, meaning who should inherit the land, can cause conflict if one child has worked the land while others want their share of the estate. Natvig, a dispute over a family farm. In its opinion No. Michael’s siblings and two children of a late sibling had argued that the transfer was the product of undue influence and that the estate planning should be set aside. Godfrey and his wife, Theodora, had eight children. Farming was very important to Godfrey and Michael lived and worked on the farm with his father for many years. These details come from the Iowa Court of Appeals’ opinion. Godfrey’s other children and two of his grandchildren challenged the arrangements. They alleged fraud, undue influence and duress and claimed that an insane delusion shaped Godfrey’s estate planning. They also challenged Michael’s actions as their father’s attorney-in-fact, a role that let him make certain decisions for Godfrey, including what they described as gifts Michael made to himself. Both courts accepted Michael’s explanation that the money went to Godfrey’s care and expenses or was spent at Godfrey’s direction. Godfrey’s lawyer, Erik Fern, testified about their discussion of why Godfrey wanted Michael to have the land. The court also rejected the insane-delusion argument. The siblings disputed Godfrey’s belief about what his children intended to do with the land, but the court found that the belief did not amount to an insane delusion, which Iowa law defines as a belief with no basis in reason that cannot be dispelled by argument. The court of appeals affirmed the district court’s dismissal, leaving the farmland transfer and Godfrey’s estate plan intact. The decision did not mean that a parent can always leave a family farm to one child without challenge. The ruling rested on the facts presented in this case. The full opinion is available on the Iowa Judicial Branch website . The Natvig case illustrates the problems that can arise when a family farm passes from one generation to the next. A parent may see a transfer to the child who works the farm as recognition of years of hard work and care, as well as a way to preserve the property. Other children may see the same move as an unfair distribution of family assets. Independent legal advice, a clear record of the owner’s intentions and evidence that the decision was voluntary can play a significant role in such cases. The court looked at the circumstances of the transfer and did not treat the unequal result as misconduct in itself. For Godfrey Natvig, preserving the farm was the main concern and the Court of Appeal left the transfer standing as he had chosen.
