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SettleADebt — S_IA PASS-08
Ordinary consumer-debt limitation, accrual, acknowledgment, payment, and judgment-duration gateway
Fresh research date: October 27, 2026, America/Los_Angeles and UTC.
Observed session clock readings: 09:41:15–10:02:56 PDT, corresponding to 16:41:15–17:02:56 UTC. These are observed session readings, not individual source-fetch timestamps.
Scope: Ordinary unsecured consumer obligations and the necessary judgment-duration distinctions. This is a same-coordinator research component, not independent review. P04 and P06 remain unreviewed and supply no premises. Earlier provider-fee, licensing, bond, agreement, and correction findings remain confined to their original scopes.
Principal finding: Iowa does not have one universal “consumer-debt clock.” The ordinary starting periods are five years for unwritten obligations and ten years for written contracts, but classification, accrual, installment maturity, valid acceleration, statutory revival, foreign-law predicates, and procedural preservation must each be established. An ordinary court-of-record money judgment introduces a different twenty-year framework; its statutory real-estate lien ordinarily has a separate ten-year duration. Iowa Legislature+2
The source register contains 32 source groups, including 15 published opinions and one separately qualified unpublished opinion. This answer includes 48 claim entries, four worked models, 22 smaller postures, and 44 coverage entries. Repeated sections or alternate formats of the same authority are grouped rather than counted as independent corroboration.
Throughout, S001 means S_IA-P8-S001, and C001 means S_IA-P8-C001.
A. Classification, accrual, and the current-law qualification
A1. The 2026 compilation requires a later-enactment qualification
The published 2026 Code’s introductory language in §614.1 was amended by 2026 Iowa Acts chapter 1150, Senate File 512, approved June 2, 2026 and effective July 1, 2026. The amendment preserves existing law governing accrual—including discovery and related statutory or common-law doctrines—and provides that the specified time limitations may be altered only by an act of the General Assembly. It does not replace the ordinary five-, ten-, or twenty-year periods examined here. C001; S001–S003. Iowa Legislature+1
The act contains no separate transition paragraph resolving every pending or previously accrued claim. Iowa Code §4.5 supplies a presumption of prospective operation unless expressly retrospective. No post-July 1, 2026 controlling construction was located resolving every interaction between the new language, contractual limitation provisions, and equitable doctrines. The existing accrual doctrines should not be described as abolished; nor is every possible equitable extension certified unchanged. Iowa Legislature+1
A2. Classification and accrual matrix
| Obligation or theory |
Starting period and trigger |
Required classification evidence |
What cannot be assumed |
| Ordinary unwritten contract |
Five years under §614.1(4), measured from legally established accrual. |
Actual obligation, performance due, breach, and any controlling conditions. |
Every unsigned document is necessarily an unwritten contract; every demand date is accrual. C002. |
| Written contract |
Ten years under §614.1(5)(a), subject to special statutory categories. |
The writings must establish the essential contractual obligation; identification and authentication remain necessary. |
A signature anywhere in a file establishes every debt term or a ten-year period. C003–C004. |
| Electronic contract |
Electronic form does not itself defeat writing/signature status. The underlying contract classification still governs. |
Applicable electronic-transaction law, attribution, assent, incorporated terms, and the actual obligation. |
A screenshot, typed name, attached generic terms, or database flag automatically proves assent. C005. |
| Credit-card account |
No uniform five- or ten-year answer was established for every card account. |
Actual governing terms, debtor linkage, assent, obligation, claim theory, and accrual facts. |
Every card is an open account, or every card agreement is a qualifying written contract. C006. |
| Continuous, open, current account |
Section 614.5 fixes accrual at the last qualifying item proved at trial; the applicable period still depends on the obligation. |
A genuinely continuous account and a legally relevant last item. |
A unilateral bookkeeping charge, collection transfer, or later cash transaction necessarily extends the old account. C007. |
| Account stated |
It is a potentially available claim theory, not an automatic new ten-year clock. |
Actual assent to an account balance and the necessary legal predicates; limitations remain separately analyzed. |
Silence after any statement creates an enforceable replacement contract or revives an already barred debt. C008. |
| Qualifying Article 3 time instrument |
Iowa §554.3118(1)(a) places accrual against the maker/acceptor on the day after maturity. The applicable limitations period must be found elsewhere. |
Actual Article 3 instrument, maturity, party liable, and any effective acceleration. |
Importing the uniform UCC’s commonly cited six-year period into Iowa. C009. |
| Qualifying demand instrument |
Section 554.3118(1)(b) uses the instrument’s date, or issue date if undated. |
Instrument status, date/issue date, and any special instrument exception. |
Waiting indefinitely to demand payment postpones accrual. C009. |
| Installment obligation |
Separately matured installments ordinarily have separate accrual dates; valid acceleration can affect the unmatured balance. |
Payment schedule, default, acceleration language, election, notices, waiver, and maturity. |
First missed payment automatically accelerates everything. C010–C012. |
| Sale-of-goods obligation |
Iowa §554.2725 refers to chapter 614 rather than supplying the uniform four-year period. It contains its own accrual and contractual-reduction provisions. |
Actual Article 2 transaction and applicable agreement. |
Importing another state’s UCC period or savings rule. C044. |
| Claim for rent |
Five years under §614.1(5)(b), notwithstanding the general written-contract provision. |
Actual rent claim rather than another contractual obligation. |
Every written consumer obligation has ten years. C003. |
The statutory periods and open-account rule are directly supported by §§614.1 and 614.5. The instrument and goods distinctions come from Iowa’s actual UCC text, not a model-code summary. Iowa Legislature+3
A3. Writing, signature, and proof are different questions
Matherly v. Hanson requires examination of whether the writings establish the obligation sued upon; a collection of papers does not become a written contract merely because some pages contain signatures or initials. Extrinsic evidence identifying a document or supplying incidental detail is different from oral evidence needed to create the essential obligation. C004; S015. Justia Law
Iowa’s electronic-transaction provisions recognize qualifying electronic records and signatures but preserve substantive law and attribution requirements. Their scope excludes most UCC transactions, including Article 3 transactions, except as otherwise provided by the specified statutory exceptions. Accordingly, this pass does not apply UETA indiscriminately to every electronic note. C005; S032. Iowa Legislature+2
The unpublished Gemini Capital Group v. New decision is useful only within those limits: its majority found the particular generic card agreement and other evidence insufficient to establish the written-contract category. It does not announce that every Iowa card debt has five years. Its citation status is separately qualified below. C006; S016. Justia Law
A4. Installments, acceleration, maturity, and cure
Frenzel distinguishes separately due installments from an unexercised acceleration option. Dunn demonstrates that contractual acceleration can also be affected by a course of accepting late payments. Neither supports treating every phrase containing “shall become due” as a self-executing acceleration regardless of the rest of the agreement. C010–C011; S022–S023. Justia Law+1
For transactions actually covered by Iowa Consumer Credit Code article 5, §§537.5109–.5110 impose additional default and cure conditions. Among the material branches are the payment-default threshold, required cure notice where a right to cure exists, a generally twenty-day post-notice restriction on acceleration/enforcement, and exceptions for specified prior notices and other circumstances. A premature money-judgment action can require dismissal without prejudice. C012; S005. Iowa Legislature+2
That does not establish that twenty days must simply be added to every installment limitation calculation. Transaction coverage, a valid notice, the particular obligation, and the legal effect on accrual must be established. Section 537.5111’s complete notice requirements were not analyzed here.
Charge-off, sale, collection placement, or a later demand is not automatically accrual. Those events may be evidence, but the legal trigger remains the applicable obligation’s breach, maturity, qualifying account item, or effective acceleration. C013.
A5. Burden and validity boundary
Limitations is ordinarily a defense requiring proper assertion; Rule 1.419 requires matters avoiding a pleading’s legal effect to be specifically pleaded. A creditor relying on revival must prove the qualifying facts; Schroedl’s later appeal specifically placed the revival issue on the claimant by a preponderance of the evidence. C016, C043. Iowa Legislature+1
A forged obligation, wrong-person account, released balance, discharged personal liability, or nonexistent debt presents a validity or enforceability issue, not a debt made valid by the passage of time. Conversely, uncertainty about validity does not itself establish a limitations defense. No actual obligation, authentic agreement, account balance, or assignment is supplied.
B. Acknowledgment, new promise, payment, and transfer
B1. Iowa’s statutory revival rule
Section 614.11 provides two routes for contract claims: a signed written admission by the party to be charged that the debt is unpaid, or a similarly signed written new promise to pay. The statute does not say that every payment revives the debt. C014–C018; S001. Iowa Legislature
| Event |
Conditional legal consequence |
Necessary evidence or remaining limitation |
| Signed writing clearly identifying an unpaid debt |
Can satisfy §614.11 even without using the word “revive.” |
Authorship/signature, identity of debt, content, qualifications, and timing. |
| Signed new promise |
Potential revival; a conditional or future-dated promise requires analysis of its actual terms. |
No uniform immediate-accrual assumption for every new promise. |
| Bare partial or interest payment |
Not sufficient by itself under the Iowa decisions read. |
A separate qualifying signed admission or promise may exist, but must be proved. |
| Signed tax return or other third-party writing |
Can provide evidence of acknowledgment when linked to the particular debt. |
It need not have been addressed to the creditor, but ambiguous interest/dividend entries may fail. |
| Attorney’s pleading or settlement communication |
No automatic imputation of a qualifying personal acknowledgment. |
Authority, signature, content, and whether unpaid liability is actually admitted. |
| Collector credit, adjustment, or sale-price entry |
Not a debtor payment or acknowledgment merely because it appears in the ledger. |
Actual source, authorization, purpose, and underlying transaction. |
| Co-obligor, family member, trustee, insurer, or representative payment |
No universal revival of every obligor’s liability. |
Identity of the party charged and legally sufficient authority or personal signed admission. |
Estate of Brooks rejects bare payment/oral-promise revival; Schroedl distinguishes payment from a qualifying written acknowledgment; Buttolph rejects reliance on the particular attorney-signed pleading and unilateral account entries before it. C015–C017. Justia Law+3
B2. Before expiry, after expiry, and resulting period
The revival doctrine is not confined to events before the original bar: the statute speaks of revival, and the Schroedl litigation expressly concerned an otherwise barred note. But a payment after expiry is still not sufficient by itself. C014–C018. Justia Law+1
For the written-note model below, a new ten-year calculation is shown only on the stipulated finding that an unconditional, effective §614.11 acknowledgment revives that same written-note claim from the acknowledgment date. This is not a universal rule that any letter concerning an oral debt creates a new ten-year contract. A conditional promise, novation, disputed identity, or future payment date can require a different analysis.
Settlement discussions are likewise not automatically revival, tolling, or estoppel. A signed communication might contain a sufficient acknowledgment, while a disputed or conditional offer might not. No categorical rule is drawn from the heading “settlement communication.”
B3. Assignment and debt sale
Rule 1.205 expressly preserves defenses against an assignor in cases outside the UCC, subject to its stated conditions. A purchaser’s payment to acquire a portfolio is not the consumer’s payment. Neither the sale date nor the purchaser’s acquisition price is a statutory acknowledgment by the debtor. C019; S006. Iowa Legislature
This does not establish chain of ownership, standing, admissibility, UCC holder status, or the amount transferred. It also does not mean assignment can never affect a statutory duration: the special rent-judgment assignment provision in §615.1A is an important counterexample discussed below.
B4. Bankruptcy is a separate boundary
Section 524’s discharge injunction and reaffirmation requirements are not displaced by Iowa revival doctrine. Voluntary repayment is permitted by §524(f), but voluntary repayment alone does not establish an enforceable reaffirmation. Section 524(e)’s treatment of other entities also prevents assuming that one debtor’s discharge resolves every co-obligor’s liability. C026. US Code
A bankruptcy distribution, trustee payment, or other involuntary application of money is not automatically the debtor’s signed acknowledgment. No actual discharge, reaffirmation, stay, or representative authority is supplied.
C. Borrowing, tolling, savings, and procedural preservation
C1. Choice of law and borrowing are not a shortest-period formula
Cameron v. Hardisty applies Iowa’s general forum-limitations approach while distinguishing substantive choice-of-law questions. Section 614.7 separately recognizes a complete foreign bar under its residency and non-Iowa-accrual conditions. It expressly excludes causes arising within Iowa. C020–C021. Justia Law+1
The necessary questions are separate:
| Question |
Required determination |
| What forum is hearing the action? |
Iowa state-court rules are not automatically federal, tribal, or foreign-court rules. |
| Where did the cause arise? |
Relevant to §614.7; an online transaction does not supply its own legal location. |
| Where did the defendant previously reside? |
Must satisfy the actual borrowing provision, not merely creditor headquarters. |
| Is the claim fully barred there? |
Foreign period, accrual, tolling, revival, and application law must be proved. |
| Is foreign law substantive or procedural? |
A substantive extinguishment/repose rule can present a different question. |
| What does the choice-of-law clause cover? |
The actual wording and enforceability matter; Cameron did not decide every consumer choice clause. |
No actual foreign jurisdiction, residence history, contract clause, or foreign-law body is supplied. Accordingly, this pass establishes the analytical gateway, not a universal shorter/longer-period selection.
C2. Tolling and related doctrines
| Doctrine |
Verified boundary |
What remains fact-dependent |
| Claimant disability/minority, §614.8 |
Provides specified extensions in favor of protected claimants, generally allowing one year after the disability ends or majority, subject to exceptions. |
Qualification, timing, claimant identity, and special statutory exceptions. It is not automatic tolling because the debtor becomes ill. C022. |
| Nonresident defendant, §614.6 |
Text excludes specified nonresident time; Kokenge construed its predecessor in light of continued amenability to Iowa service. |
Modern application to the particular debtor and available service; do not mechanically add every absence. C023. |
| Unknown defendant |
Section 614.6’s unknown-person branch concerns specified personal-injury/death criminal conduct and diligent identification efforts. |
It is not a general extension for an unidentified debt purchaser or missing address. C023. |
| Fraud/mistake discovery, §614.4 |
Applies to its specified causes; discovery is an accrual question where applicable. |
No universal rule delaying ordinary collection accrual until a creditor discovers default. C024. |
| Fraudulent concealment/equitable estoppel |
Downing distinguishes estoppel from accrual and clock-running; requires proof of the applicable concealment, ignorance, intent, and detrimental reliance elements. |
The case was a medical-repose action; application to ordinary debt and the 2026 amendment remains qualified. C024. |
| Injunction/statutory prohibition, §614.13 |
Excludes the time during which commencement is prohibited, subject to chapter exceptions. |
Actual prohibition, covered action, dates, and exception. C025. |
| Bankruptcy, §108(c) |
Uses the later of the applicable period, including legally applicable suspension, or thirty days after notice of the specified stay termination. |
It does not itself justify blindly adding the entire bankruptcy duration. C026. |
| SCRA, 50 U.S.C. §3936 |
Excludes qualifying military-service periods for specified actions by or against protected persons; tax exception applies. |
Actual service qualification and dates; state-only National Guard provisions were not completed. C027. |
Sources: §§614.4, .6, .8, .13; Kokenge; Downing; 11 U.S.C. §108(c); 50 U.S.C. §3936. Iowa Legislature+5
C3. Filing, service, savings, and relation back
Ordinary district-court commencement: Rule 1.301(1) uses filing of the petition to commence the action and determine the limitations commencement time. Small claims differs: §631.3 uses filing an original notice. Neither observation eliminates subsequent service requirements. C028. Iowa Legislature+1
Service: Rule 1.302(5) establishes a ninety-day service framework. After notice, the court may dismiss without prejudice or direct another time or manner of service; a showing of good cause requires an appropriate extension. Rucker applies good cause to its particular communications and conduct, not to every negotiation or inadvertent delay. C029. Iowa Legislature+1
Savings: Section 614.10 allows a qualifying second action within six months after failure of the first, except failure through negligence in prosecution. Furnald rejected the particular strategic voluntary dismissal; Trask, decided May 29, 2026, permitted savings where dismissal followed legal futility rather than negligent prosecution. “Without prejudice” is not synonymous with “automatically entitled to six more months.” C030. Iowa Legislature+2
Relation back: Rule 1.402(5) requires the same conduct, transaction, or occurrence. Changing a defendant additionally requires the rule’s timely notice, lack of prejudice, and mistake-related knowledge conditions. Filing against the wrong person is not automatically repaired after expiry. C031. Iowa Legislature
Counting: Section 4.1(34), read with Rule 1.1801, excludes the first day and includes the last, with specified weekend, holiday, and clerk-closure treatment. Months are calendar months; years are twelve months. The models do not substitute thirty days for a month or assume every federal holiday is an Iowa statutory holiday. C032. Iowa Legislature+1
D. Judgment duration without collapsing the clocks
D1. Distinct legal objects
| Object |
Ordinary rule or mechanism |
Essential qualification |
| Underlying contract claim |
Five or ten years, depending on classification and exceptions. |
This is not the post-judgment clock. |
| Action on a court-of-record judgment |
Twenty years under §614.1(6). |
Support and marital-distribution exceptions; special judgment statutes remain separate. C033. |
| Judgment of a court not of record |
Ten-year category under §614.1(5)(a). |
Do not equate every small claim with a non-record judgment. C034. |
| Early action on an Iowa court-of-record judgment |
Within nine years, §614.3 requires leave for good cause and reasonable notice to an Iowa-resident adverse party. |
The restricted period is not excluded from the twenty-year calculation. C035. |
| Ordinary statutory real-estate judgment lien |
Ten years from the judgment under §624.23(1). |
Attachment, property exclusions, and recording conditions remain separate. C036. |
| Lien in another Iowa county |
Section 624.24 requires filing the specified attested judgment copy there. |
Later recording does not establish a new ten-year judgment date. C036. |
| Obtaining a new judgment/lien |
A separate action on the original judgment, with entitlement and procedural requirements, is the recognized route. |
A motion alone cannot extend the original lien. C037. |
| Execution |
Section 626.2 permits execution before the judgment is barred. |
A still-enforceable judgment does not prove available assets or a particular levy right. C038. |
| Individual execution return |
Section 626.16 requires return on or before the 120th day after issuance. |
This is not the judgment’s twenty-year life; §626.27 separately preserves specified garnishment proceedings despite expiration/return. C038. |
| Full satisfaction |
Section 624.37 requires acknowledgment and filing in each county where the judgment is a lien. |
Expiration, satisfaction, release, and actual unpaid balance are different facts. C040. |
Sources: §§614.1(5)–(6), .3; §§624.23–.24, .37; §§626.2, .16, .27. Iowa Legislature+6
D2. “Renewal” must describe the actual mechanism
In Whitters, the Supreme Court rejected an attempted lien extension by motion and identified a separate action on the judgment as the route to obtaining a new lien. It did not create an automatic renewal entitlement or an evergreen judgment. C035–C037; S030. FindLaw Caselaw+1
The reviewed ordinary provisions did not establish a separate short dormancy period that automatically replaces the twenty-year framework. That is a bounded finding, not a certification covering every special judgment, stay, execution, or historical transition.
The current §614.3 text also retains a historical justice-of-the-peace judgment clause. It should not silently be rewritten as a rule governing all modern small claims.
D3. Assignment can matter in special judgment categories
Section 615.1A creates a material exception for rent judgments sold or assigned for value to certain third parties: the statute supplies a two-year period from original judgment entry, excluding specified stays, with the stated bank/credit-union exception. Its general rent-judgment and special-assignment branches must be read together. C039. Iowa Legislature
This defeats a universal statement that judgment assignment can never affect duration. It does not establish the treatment of any actual sale or old judgment; the pertinent 2013/2018 enactment-application history was not fully traced.
Sections 615.1–.3 contain other special secured-obligation restrictions. Those are identified as exclusions from the ordinary model, not analyzed as foreclosure or secured-debt merits.
D4. Satisfaction and actual ownership
A new owner must establish the rights actually transferred; assignment does not itself create a new judgment date. A new judgment does not authorize double collection of the same unpaid obligation.
Section 624.37’s full-satisfaction instrument and county filings address the public record. The statute also contains a request-based enforcement mechanism; this pass does not calculate penalties, interest, payoff amounts, or actual satisfaction. C040. Iowa Legislature
For a small-claims judgment ordering installments, §631.12 additionally restricts execution while payments comply and requires the specified default affidavit before enforcement. This is a payment/enforcement condition, not a new limitations period. C045. Iowa Legislature
D5. Federal collection and reporting boundaries
Regulation F: For an actor and debt covered by the rule, §1006.26 prohibits bringing or threatening legal action on time-barred debt. Its bankruptcy-proof-of-claim exception is express. It is not a universal rule governing every original creditor or every bankruptcy collection act. No withdrawn CFPB guidance is used; this finding rests on the operative regulation. C041. eCFR
FCRA: Collection/charge-off reporting ordinarily uses the delinquency immediately preceding collection or charge-off and the statutory seven-year/180-day structure, subject to statutory exceptions. It is not restarted merely by a debt sale or state-law acknowledgment. Civil-judgment reporting has different statutory wording, and actual bureau reporting practices were not investigated. C042. US Code
E. Source register, part 1 — statutes, rules, and enacted-law status
Common access record for every row: Freshly accessed October 27, 2026 PDT/UTC during the observed session identified above. Exact individual fetch times are not assigned. Selected bodies were read; “fresh” does not mean a complete chapter, amendment-chain, or citator audit.
| Source ID |
Issuer/title and full literal HTTPS URL(s) |
Material body read; pinpoint and version |
Status/read limits |
| S_IA-P8-S001 |
Iowa Legislature, 2026 Code ch. 614. https://www.legis.iowa.gov/docs/code/2026/614.pdf Section copies: https://www.legis.iowa.gov/docs/code/2026/614.1.pdf https://www.legis.iowa.gov/docs/code/2026/614.5.pdf https://www.legis.iowa.gov/docs/code/2026/614.6.pdf https://www.legis.iowa.gov/docs/code/2026/614.7.pdf https://www.legis.iowa.gov/docs/code/2026/614.8.pdf https://www.legis.iowa.gov/docs/code/2026/614.10.pdf https://www.legis.iowa.gov/docs/code/2026/614.11.pdf https://www.legis.iowa.gov/docs/code/2026/614.13.pdf |
§§614.1(4)–(6), .3–.13 and necessary exceptions; chapter printed pp.2, 4–6, PDF indices1,3–5. Relevant chapter/section pages visually inspected. Chapter footer Dec.9,2025; section copies Dec.12,2025. |
Compilation supplemented by S002. HTML route failed; §614.3 individual PDF timed out, but its complete body was recovered in chapter PDF. Not all 17 pages analyzed. |
| S_IA-P8-S002 |
Iowa Legislature, 2026 Acts ch.1150 / SF512. https://www.legis.iowa.gov/docs/publications/iactc/91.2/CH1150.pdf https://www.legis.iowa.gov/docs/publications/LGE/91/attachments/SF512.html https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=SF512&ga=91 |
Complete one-page act/PDF index0, enrolled text, official passage/approval/effective history. |
Approved June2; effective July1,2026. Actual act visually inspected. No separate transition clause found in this act; no complete session-law audit. |
| S_IA-P8-S003 |
Iowa Legislature, 2026 Code ch.4. https://www.legis.iowa.gov/docs/code/2026/4.html |
§4.1(16), (34), (39), (40); §4.5. |
Fresh selected HTML bodies; counting and prospective-operation qualifications only. |
| S_IA-P8-S004 |
Iowa Legislature, Iowa UCC. https://www.legis.iowa.gov/docs/code/2026/554.3118.pdf https://www.legis.iowa.gov/docs/code/2026/554.2725.pdf |
Complete one-page sections, each printed p.1/PDF index0; visual inspection. |
Iowa-specific accrual and limitation-reference text. Article3/Article2 transaction qualification and full historical transitions not certified. |
| S_IA-P8-S005 |
Iowa Legislature, Consumer Credit Code enforcement gateway. https://www.legis.iowa.gov/docs/code/2026/537.5102.pdf https://www.legis.iowa.gov/docs/code/2026/537.5109.pdf https://www.legis.iowa.gov/docs/code/2026/537.5110.pdf |
Complete selected sections; §.5110 printed pp.1–2/indices0–1, including exceptions and subsection7; relevant pages visually inspected. |
No complete chapter537, charter, transaction-exemption, or §537.5111 notice-form analysis. |
| S_IA-P8-S006 |
Iowa Legislature/Judicial Branch, Civil Procedure Rules. https://www.legis.iowa.gov/docs/ACO/CourtRulesChapter/1.pdf Index: https://www.legis.iowa.gov/law/courtRules/courtRulesListings Orders: https://www.iowacourts.gov/iowa-courts/supreme-court/orders |
Rules1.205,1.301,1.302(5),1.402(5),1.419,1.1801; printed pp.1,16–17,22,25,85/PDF indices10,25–26,31,34,94. Selected pages visually inspected. |
Official index labeled2026; retrieved chapter bears July2023 footer. Bounded later-order checks did not establish a change to relied-on clauses; not a complete later-order audit. Alternative /docs/rules/current/court/1.pdf route failed. |
| S_IA-P8-S007 |
Iowa Legislature/Judicial Branch, Appellate Procedure Rules. https://www.legis.iowa.gov/docs/ACO/CourtRulesChapter/6.pdf |
Rule6.904(2)(a)(2), printed p.26/PDF index29, visually inspected. |
December2025 compilation; used only to qualify unpublished-opinion use. |
| S_IA-P8-S008 |
Iowa Legislature, 2026 Code ch.624. https://www.legis.iowa.gov/docs/code/2026/624.html https://www.legis.iowa.gov/docs/code/2026/624.23.pdf https://www.legis.iowa.gov/docs/code/2026/624.24.pdf https://www.legis.iowa.gov/docs/code/2026/624.37.pdf |
§§624.20, .23, .24–.26, .37; selected complete bodies. SectionPDFs pp.1–2/indices0–1 where applicable; pertinent pages visually inspected. |
Lien duration/recording/satisfaction only. Homestead, priority, recognition, and special-support merits excluded. |
| S_IA-P8-S009 |
Iowa Legislature, 2026 Code ch.626. https://www.legis.iowa.gov/docs/code/2026/626.pdf |
§§626.1–.5, .16, .27; printed pp.2,4,6/PDF indices1,3,5, visually inspected. |
HTML route failed; PDF recovered text. Not a full execution/garnishment review. |
| S_IA-P8-S010 |
Iowa Legislature, 2026 Code ch.615. https://www.legis.iowa.gov/docs/code/2026/615.html |
§§615.1–.4, particularly complete §615.1A. |
Special-category boundaries; underlying2013/2018 application history not fully read. |
| S_IA-P8-S011 |
eCFR, 12 CFR1006.26. https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-B/section-1006.26 |
Complete subsections(a)–(c). |
Display current through Oct.23,2026. Actor/debt coverage and other FDCPA provisions remain conditional; no guidance relied upon. |
| S_IA-P8-S012 |
U.S. House OLRC, 15 USC1681c. https://uscode.house.gov/us/usc/119-118/t15/s1681c/ |
(a)(2),(4), (b), (c), including effective/application language. |
Display through Pub.L.119-120, Oct.7,2026. Statutory obsolescence only; bureau policies and complete FCRA not reviewed. |
| S_IA-P8-S013 |
U.S. House OLRC, 11 USC108 and524. https://uscode.house.gov/us/usc/119-118/t11/s108/ https://uscode.house.gov/us/usc/119-118/t11/s524/ |
§108(a)–(c); §524(a), complete(c), pertinent(d)–(f). |
Display through Oct.7,2026. Reaffirmation/discharge/stay gateway only; no bankruptcy case or order supplied. |
| S_IA-P8-S014 |
U.S. House OLRC, 50 USC3936. https://uscode.house.gov/us/usc/119-118/t50/s3936/ |
Complete section, tax exception and application note. |
Military-period boundary only; actual service eligibility and Iowa National Guard statute unverified. |
| S_IA-P8-S031 |
Iowa Legislature, Small Claims. https://www.legis.iowa.gov/docs/code/2026/631.3.pdf https://www.legis.iowa.gov/docs/code/2026/631.12.pdf |
Complete one-page sections/PDF index0 each; visually inspected. |
Original-notice commencement and installment-judgment enforcement boundary; no full small-claims service/default review. |
| S_IA-P8-S032 |
Iowa Legislature, 2026 Code ch.554D. https://www.legis.iowa.gov/docs/code/2026/554D.pdf |
§§554D.103(7)–(8), .104, .106, .108, .111; printed pp.2–4/PDF indices1–3 visually inspected. |
Fresh narrow classification/attribution read, not reuse of unreviewed P06. UCC scope exclusion preserved; no disclosure rerun. |
E2. Primary case matrix and source register, part 2
Publication and read qualification: The following rows concern actual judicial opinion bodies, not publisher summaries. Justia and FindLaw are disclosed republication hosts. Except for the explicit unpublished row, these are published Iowa appellate opinions. No complete citator or later-law certificate is claimed. Historical statutory numbering is not substituted for the current sections.
| Source ID / opinion and full URL |
Court, date, publication/citation |
Actual body read and narrow holding |
Disposition and limits |
| S_IA-P8-S015 — Matherly v. Hanson https://law.justia.com/cases/iowa/supreme-court/1984/83-1562-0.html |
Iowa Supreme Court, Dec.19,1984; 359 N.W.2d450. |
Majority’s written-contract and estoppel analysis, pp.454–458. Papers did not establish the essential written obligation needed for the longer period. |
Summary judgment affirmed. Dissent not adopted; no blanket unsigned-contract rule. Justia Law |
| S_IA-P8-S016 — Gemini Capital Group, LLC v. New https://law.justia.com/cases/iowa/court-of-appeals/2011/1-521.html |
Iowa Court of Appeals, Sept.8,2011; No.10-1096, unpublished; Doyle majority, separate concurrence/dissent. |
Majority slip pp.2–7. Generic agreement and the presented account evidence did not establish the written-contract category. |
Reversed/remanded. Reasoning only under Rule6.904; not controlling and not counted among the15 published opinions. Justia Law |
| S_IA-P8-S017 — Capital One Bank (USA), N.A. v. Denboer https://www.iowacourts.gov/moduledocuments/embed/18628/91046_A30BA3500EA35.pdf |
Iowa Court of Appeals, Aug.25,2010; 791 N.W.2d264, No.09-0354. |
Official majority PDF; account-stated analysis, printed pp.11–18/indices10–17, and disposition. Account stated may be available subject to statutory proof requirements. |
Reversed/remanded dismissals. Not a limitations holding and not proof every statement creates a new contract. Iowa Judicial Branch |
| S_IA-P8-S018 — Buttolph v. Geeseka https://law.justia.com/cases/iowa/supreme-court/1950/47706-0.html |
Iowa Supreme Court, Oct.17,1950; 44 N.W.2d434. |
Majority pp.435–436. Later cash dealings/unilateral entries did not extend the earlier account; the particular attorney pleading did not establish revival. |
Affirmed. Historical subsection numbering; no universal ruling on all authorized representative signatures. Justia Law |
| S_IA-P8-S019 — In re Estate of Brooks https://law.justia.com/cases/iowa/supreme-court/1959/49670-0.html |
Iowa Supreme Court, Mar.10,1959; 95 N.W.2d287. |
Majority §IV, pp.290–291. Partial payment/oral promise did not replace required signed written acknowledgment. |
Affirmed. Probate facts; no general estate-claim deadline imported. Justia Law |
| S_IA-P8-S020 — Schroedl v. McTague (1964) https://law.justia.com/cases/iowa/supreme-court/1964/51223-0.html |
Iowa Supreme Court, June9,1964; 129 N.W.2d19. |
Majority pp.21–23. Tax-return evidence could support acknowledgment when sufficiently tied to the note; originals’ signatures were established and copy objections were not raised. |
Directed verdict reversed; remanded for factfinding, not automatic revival judgment. Justia Law |
| S_IA-P8-S021 — Schroedl v. McTague (1969) https://law.justia.com/cases/iowa/supreme-court/1969/53281-0.html |
Iowa Supreme Court, July24,1969; 169 N.W.2d860. |
Majority §IX, pp.866–867. Claimant had to connect the signed entries to interest on the particular note and prove revival; payment alone was insufficient. |
Defense verdict affirmed. The intervening1966 opinion was not independently read. Justia Law |
| S_IA-P8-S022 — Frenzel v. Frenzel https://law.justia.com/cases/iowa/supreme-court/1967/52293-0.html |
Iowa Supreme Court, July11,1967; 152 N.W.2d157. |
Majority installment/acceleration discussion, pp.158–160, §§II–VI. Instruments read together; acceleration was not self-executing. |
Affirmed. Secured-note facts used only for accrual doctrine; historical foreclosure rules not imported. Justia Law+1 |
| S_IA-P8-S023 — Dunn v. General Equities of Iowa, Ltd. https://law.justia.com/cases/iowa/supreme-court/1982/66050-0.html |
Iowa Supreme Court, May19,1982; 319 N.W.2d515. |
Majority §§I–II, pp.516–518. Prior acceptance of late payments supported waiver of acceleration on the record. |
Affirmed. Not a universal consumer notice rule or an independent limitations-period decision. Justia Law |
| S_IA-P8-S024 — Cameron v. Hardisty https://law.justia.com/cases/iowa/supreme-court/1987/86-1307-0.html |
Iowa Supreme Court, June17,1987; 407 N.W.2d595. |
Majority pp.596–598. Applied Iowa forum limitation to certified multistate accident facts. |
Certified question answered. Does not decide every contractual choice clause or foreign substantive extinguishment. Justia Law |
| S_IA-P8-S025 — Kokenge v. Holthaus https://law.justia.com/cases/iowa/supreme-court/1952/47954-0.html |
Iowa Supreme Court, Apr.1,1952; 52 N.W.2d711. |
Majority pp.711–713. Continued amenability to Iowa motorist service defeated the claimed nonresidence extension. |
Bar applied. Historical motorist/predecessor-statute context; modern ordinary-debt application remains fact-dependent. Justia Law |
| S_IA-P8-S026 — Downing v. Grossmann https://caselaw.findlaw.com/court/ia-supreme-court/2170410.html |
Iowa Supreme Court, Apr.22,2022; No.20-1124, published opinion. |
Majority §III, displayed HTML lines95–132. Distinguished repose, accrual, and estoppel; required subsequent independent concealment under the applicable doctrine. |
Court of Appeals vacated; district judgment affirmed. Reporter pagination not verified; medical period not imported into debt law. FindLaw Caselaw+1 |
| S_IA-P8-S027 — Furnald v. Hughes https://law.justia.com/cases/iowa/supreme-court/2011/10-0180.html |
Iowa Supreme Court, Sept.30,2011; 804 N.W.2d273. |
Majority savings analysis, pp.276–282. Strategic voluntary dismissal under the particular circumstances did not satisfy §614.10. |
Affirmed. Read with Trask; not all voluntary dismissals are categorically excluded under §614.10. Justia Law |
| S_IA-P8-S028 — Trask v. Ahmed https://law.justia.com/cases/iowa/supreme-court/2026/25-0671.html https://cases.justia.com/iowa/supreme-court/2026-25-0671.pdf?ts=1780063498 |
Iowa Supreme Court, May29,2026; No.25-0671, published unanimous opinion. |
Majority printed pp.4–14/PDF indices3–13. Legal futility following intervening certificate-law development supported savings without negligent prosecution. |
Reversed/remanded. Medical certificate requirements are not generalized to debt suits; reporter citation not verified. Justia Law |
| S_IA-P8-S029 — Rucker v. Taylor https://law.justia.com/cases/iowa/supreme-court/2013/111394.html https://cases.justia.com/iowa/supreme-court/111394.pdf?ts=1396154078 |
Iowa Supreme Court, Mar.22,2013; 828 N.W.2d595. |
Majority printed pp.2–15/indices1–14. Particular communications and conduct established good cause for late service. |
Denial of dismissal affirmed; remanded. Dissent begins printed p.16 and is not relied upon. Justia Law |
| S_IA-P8-S030 — Whitters v. Neal https://caselaw.findlaw.com/court/ia-supreme-court/1231914.html |
Iowa Supreme Court, Dec.22,1999; No.98-2181, published opinion. |
Complete short majority, especially §II, displayed HTML lines71–103. Motion alone could not extend the original lien; separate action identified. |
Reversed/remanded to deny motion. Reporter pagination not verified; no automatic new-judgment entitlement. FindLaw Caselaw+1 |
Unpublished-opinion qualification
The retrieved December2025 appellate rule is 6.904(2)(a)(2). It permits unpublished opinions as persuasive reasoning, not controlling authority, and specifies docket/electronic-database citation and, when necessary, attachment requirements. Gemini is used only on that basis. No Westlaw number was verified or invented. No brief or court filing is being prepared. C046. Iowa Legislature
F. Four independently worked fictional models
Shared counting assumptions
These are fictional research models, not actual filing or payment recommendations.
Unless a branch says otherwise:
- Iowa law governs the stipulated ordinary claim.
- No discharge, fraud, release, special-sector rule, military period, disability, borrowing, or tolling applies.
- A calendar year is twelve months; a month is a calendar month.
- The triggering day is excluded and the terminal day included under the applicable counting rule.
- Listed weekday endpoints are assumed not to be statutory holidays or extraordinary clerk-closure days.
- Future endpoints assume unchanged relevant law.
- Dates are computed anniversaries under stipulated legal predicates, not a guarantee that the last instant is safe.
M01 — Signed writing versus oral/open-account/card alternatives
Stipulated written-note facts
A genuine, authenticated signed note qualifies as an Article3 time instrument. It requires three separately due installments:
Plain text
Installment 1 maturity: June 30, 2015
Installment 2 maturity: June 30, 2016
Final installment maturity: June 30, 2017
No acceleration occurs initially. Section554.3118(1)(a)’s day-after-maturity rule and the stipulated ten-year written-contract category apply.
Plain text
Installment 1:
June 30, 2015 + 1 day = July 1, 2015 accrual
July 1, 2015 + 10 calendar years = July 1, 2025, Tuesday
Installment 2:
June 30, 2016 + 1 day = July 1, 2016 accrual
July 1, 2016 + 10 calendar years = July 1, 2026, Wednesday
Final installment:
June 30, 2017 + 1 day = July 1, 2017 accrual
July 1, 2017 + 10 calendar years = July 1, 2027, Thursday
One missed installment does not, on these facts, make all three dates July1,2025. C003, C009–C010.
Effective-acceleration alternative
Assume the authentic agreement gives an enforceable option, all applicable cure/notice requirements have been satisfied, no waiver defeats it, and an effective election makes the previously unmatured balance due August3,2015.
Plain text
Accelerated maturity: August 3, 2015
Day-after accrual: August 4, 2015
Ten-year anniversary: August 4, 2025, Monday
This calculation concerns the accelerated unmatured balance. It does not silently restart an already accrued installment. If acceleration was ineffective, the original installment schedule remains the alternative requiring analysis. C011–C012.
Different-obligation alternatives
Plain text
Stipulated oral-contract accrual: July 1, 2015
Applicable period: 5 years
Computed anniversary: July 1, 2020, Wednesday
For a genuinely continuous unwritten open account with its last proved qualifying item on July1,2015, the same five-year arithmetic follows—but only after §614.5 classification is established.
For a card file containing generic unsigned terms, none of the above classifications is automatic. Missing authenticated terms or missing linkage to the debtor prevents selection of one asserted date.
Adverse branch: If a required cure notice was absent, the August acceleration date is not established. If the writings do not establish the contractual obligation, ten years is not established. The arithmetic remains correct only within its stipulated branch. Sources: S001, S004–S005, S015–S017, S022–S023. Iowa Legislature+2
M02 — Pre-expiry and post-expiry acknowledgment versus payment
Original obligation
Assume a genuine written note has established accrual on May6,2015.
Plain text
May 6, 2015 + 10 calendar years
= May 6, 2025, Tuesday
Branch A: qualifying pre-expiry acknowledgment
On May1,2025, the debtor personally signs an unconditional writing identifying the note and admitting it remains unpaid.
Assume a court finds §614.11 satisfied and a renewed ten-year period for that same written-note claim begins on that date.
Plain text
Effective acknowledgment: May 1, 2025
Stipulated renewed period: 10 years
Computed anniversary: May 1, 2035, Tuesday
Branch B: qualifying post-expiry acknowledgment
Instead, the same qualifying event occurs June5,2025, after the original anniversary.
Plain text
Original anniversary: May 6, 2025
Later acknowledgment: June 5, 2025
If statutory revival is established:
June 5, 2025 + 10 years = June 5, 2035, Tuesday
The legal predicate is actual statutory revival, not merely a later transaction. The model does not establish a new ten-year period for every acknowledgment of an oral obligation or a conditional future promise.
Branch C: no qualifying writing
The debtor makes a $25 payment after May6,2025 but signs no qualifying acknowledgment or promise.
Plain text
Bare payment alone:
No new endpoint established under the Iowa authorities read.
Original computed anniversary remains May 6, 2025.
A signed check or electronic payment record could present a different evidentiary question if its content and attribution amount to the required acknowledgment. The fact of payment alone is insufficient.
Non-debtor entries
Plain text
Collector account credit: $100
Debt purchaser's acquisition price: $200
Neither is stipulated to be money paid by the debtor, much less a signed admission by the party charged. No restart is calculated.
Adverse branches: An unauthorized family payment, an attorney’s disputed proposal, a conditional settlement offer, a writing referring to another debt, or a discharged obligation defeats the assumed simple revival calculation until the missing legal predicates are resolved. C014–C019, C026. Iowa Legislature+2
M03 — Borrowing, tolling, savings, filing, and service
These are separate alternatives, not cumulative additions to one clock.
Base Iowa branch
Plain text
Stipulated oral-contract accrual: July 15, 2020
Period: 5 calendar years
Base anniversary: July 15, 2025, Tuesday
Foreign-bar alternative
Assume—not as a finding about any actual jurisdiction—that:
- The cause arose outside Iowa.
- The defendant previously resided in the relevant foreign jurisdiction.
- Its applicable law fully bars this claim after four years.
- No foreign tolling, revival, or other exception applies.
- Section614.7 applies to the stipulated circumstances.
Plain text
July 15, 2020 + 4 years
= July 15, 2024, Monday
That foreign bar can matter even though the Iowa scalar date is July15,2025. Without those predicates, the four-year date is only a hypothetical comparison.
Statutory-prohibition alternative
Instead, retain Iowa’s five-year branch and stipulate an actual qualifying prohibition under §614.13 covering June1–June30,2025 inclusive, with no chapter exception.
Plain text
Excluded days: 30 calendar days
Base anniversary: July 15, 2025
July 16–July 31: 16 days
August 1–August 14: 14 days
Total added: 30 days
Adjusted computed endpoint: August 14, 2025, Thursday
Accrual remains July15,2020. The excluded period does not change the original accrual event.
Commencement/service alternative
Assume a regular district-court petition is filed July10,2025, before the unadjusted July15 anniversary.
Plain text
Service count begins after July 10:
July 11–31 = 21 days
August = 31 days; cumulative 52
September = 30 days; cumulative 82
October 1–8 = 8 days; cumulative 90
Ninetieth day: October 8, 2025, Wednesday
Service on October9 is outside that nominal period. The action is not automatically lost in every circumstance: Rule1.302(5)’s court-order and good-cause branches must be applied. But filing on July10 does not immunize negligent later service.
Savings alternative
Assume the timely first action legally fails on November3,2025 for a reason satisfying §614.10 and not negligent prosecution.
Plain text
November 3, 2025 + 6 calendar months
= May 3, 2026, Sunday
Assuming ordinary commencement counting applies
and the clerk is open on the next day:
Adjusted filing endpoint = May 4, 2026, Monday
This is not “180 days.” If the dismissal instead results from negligent prosecution, the model does not establish savings. A goods action may also invoke §554.2725’s differently worded savings provision.
Adverse branch: Actual foreign law, an inapplicable injunction, negligent service, or a different failure date changes the outcome. No silent switch among those branches is permitted. C020–C032, C044. Iowa Legislature+4
M04 — Entered judgment, lien, execution, and a new action
Original judgment
Assume an ordinary Iowa district-court money judgment of a court of record was rendered and properly entered on June2,2014. It is not a rent, support, marital-distribution, secured-obligation, or foreign-recognition judgment. No stay, discharge, satisfaction, or special exception applies.
Plain text
Nine-year point:
June 2, 2014 + 9 years = June 2, 2023, Friday
Ten-year original lien anniversary:
June 2, 2014 + 10 years = June 2, 2024, Sunday
Twenty-year judgment-action anniversary:
June 2, 2014 + 20 years = June 2, 2034, Friday
The Sunday lien anniversary is a fixed-duration question, not automatically a filing deadline extended to Monday. This model does not claim an extra day of lien existence.
Proper separate-action alternative
Assume the legally entitled judgment creditor commences a separate action on June5,2023, proves ownership and the unpaid judgment, complies with required process, and obtains a genuinely new judgment on October5,2023.
Plain text
New judgment date: October 5, 2023, Thursday
New lien anniversary, assuming proper attachment:
October 5, 2023 + 10 years = October 5, 2033, Wednesday
New judgment-action anniversary:
October 5, 2023 + 20 years = October 5, 2043, Monday
The new dates arise from the stipulated new judgment, not from filing a motion, recording a copy, selling the old judgment, or renewing a provider license. Actual priority and duplicate-recovery questions are not decided.
Adverse alternatives
- Only a “renewal” motion filed: Whitters does not permit that motion alone to extend the original lien.
- No new judgment obtained: The new October2023 dates do not exist.
- Assignment only: No new original judgment date is created.
- Full satisfaction: Remaining enforceability cannot be inferred from the twenty-year outer framework.
- Rent judgment assigned for value: §615.1A requires a separate analysis; this ordinary model cannot be reused.
- Original lien expired but judgment remains unbarred: The two objects remain distinct; actual execution and property rights need separate authority and facts.
- Individual writ: Its 120-day return framework is not a new twenty-year judgment period.
C033–C040. Iowa Legislature+3
G. Twenty-two smaller distinct postures
| ID / stage |
Stipulated posture and rule/source |
Conditional consequence |
Exact missing fact or gap |
| P01 — Classification |
Signed page, missing incorporated repayment terms. C004; S015. |
Signature alone does not establish the written obligation. |
Authentic complete writings and incorporation. |
| P02 — Classification |
Oral loan, alleged due date disputed. C002. |
Five-year category may apply, but no endpoint follows yet. |
Enforceable obligation and actual accrual date. |
| P03 — Card claim |
Generic card terms attached to complaint. C006; S016. |
No automatic ten-year classification. |
Debtor linkage, governing version, assent; unpublished-case limit. |
| P04 — Open account |
Creditor adds an old tax/collection charge years later. C007; S018. |
Unilateral entry need not be a new qualifying last item. |
Continuous account and legally relevant transaction. |
| P05 — Account stated |
Consumer receives a statement and does not respond. C008; S017. |
Does not automatically establish a replacement contract or new limitation. |
Actual assent and limitations treatment. |
| P06 — Installments |
First installment missed, final maturity years later. C010. |
Separate installments can have separate clocks. |
Schedule and effective acceleration. |
| P07 — Acceleration |
Contract permits election, but no election or required cure shown. C011–C012. |
Whole-balance acceleration date remains unproved. |
Authentic term, notice, cure, waiver, positive election. |
| P08 — Post-expiry payment |
Consumer pays a small amount without signed admission. C015. |
Bare payment does not establish revival. |
Any qualifying associated writing. |
| P09 — Representative payment |
Family member or co-obligor pays. C017. |
No automatic revival against another person. |
Authority and party-to-be-charged acknowledgment. |
| P10 — Negotiation |
Lawyer writes “client disputes liability but offers compromise.” C014, C017. |
No automatic unpaid-debt admission or estoppel. |
Full language, authority, signatures, reliance. |
| P11 — Sale |
Portfolio buyer pays pennies on balance. C019. |
Purchase price is not debtor payment. |
Actual transferred rights and applicable UCC exception. |
| P12 — Foreign law |
Choice clause names another state. C020–C021. |
No automatic shortest or longest period. |
Clause scope, cause location, residency, foreign law. |
| P13 — Disability |
Debtor becomes mentally ill after default. C022. |
Claimant-protection statute is not automatically creditor tolling. |
Protected claimant and statutory qualification. |
| P14 — Concealment |
Party alleges original fraud but no later concealment. C024; S026. |
Estoppel cannot be assumed from the original wrong alone. |
Required concealment, knowledge, intent, reliance; later-law application. |
| P15 — Dismissed action |
Timely suit voluntarily dismissed. C030; S027–S028. |
Savings depends on why it failed, not the label alone. |
Negligence, necessity/futility, failure date. |
| P16 — Late service |
Petition timely; ninety days pass. C029; S029. |
Dismissal/extension depends on rule and facts. |
Good cause, court direction, service record. |
| P17 — Wrong defendant |
Claimant substitutes another party after expiry. C031. |
Relation back is not automatic. |
Timely notice, mistake knowledge, prejudice. |
| P18 — Old judgment |
Original lien anniversary passed; judgment under twenty years. C033–C038. |
Lien lapse does not necessarily equal judgment bar. |
Actual dates, special category, execution conditions. |
| P19 — Reporting |
Collector buys an account and changes its internal date. C042. |
Internal sale date does not replace FCRA’s statutory delinquency trigger. |
Actual preceding delinquency, cure history, reporting exception. |
| P20 — Military |
Alleged active service overlaps limitation. C027. |
Qualifying service can exclude time. |
Statutory service status and exact dates; state Guard law separate. |
| P21 — Bankruptcy |
Voluntary payment after discharge. C026. |
Payment is not automatically enforceable reaffirmation. |
Discharge scope and §524 compliance. |
| P22 — Special forum/sector |
Tribal, foreign-country, federal-tax, or special secured judgment. C034, C039, C047. |
Ordinary Iowa model cannot be transplanted. |
Governing forum, recognition law, special statute and transition. |
These postures are applications of the identified sources, not additional independent authorities or findings about real accounts.
H. Atomic claim register — S_IA-P8-C001–C048
“High” means strong support for the stated text or narrow holding—not certainty about an unidentified account. “Conditional” identifies a rule whose application requires missing facts.
| Claim ID |
Precise proposition |
Source/pinpoint |
Predicates, consequence, confidence, exact gap |
| S_IA-P8-C001 |
Chapter1150 amended §614.1’s introduction effective July1,2026 without replacing the examined numerical periods. |
S002 §1; official history. |
High; pending-case/equitable construction not fully resolved. |
| S_IA-P8-C002 |
Ordinary unwritten-contract actions fall within five years under §614.1(4). |
S001 §614.1(4). |
High; accrual and statutory exceptions required. |
| S_IA-P8-C003 |
Written-contract category is ten years; rent claims have a five-year exception. |
S001 §614.1(5)(a)–(b). |
High; actual category unproved. |
| S_IA-P8-C004 |
A writing must establish the essential obligation; signatures or miscellaneous papers alone are insufficient. |
S015 pp.454–457. |
High narrow holding; actual writings absent. |
| S_IA-P8-C005 |
Qualifying electronic records/signatures may count, but attribution, scope, and substantive contract law remain necessary. |
S032 §§.103,.104,.106,.108,.111. |
High; UCC exclusions and actual assent held. |
| S_IA-P8-C006 |
Card limitation cannot be assigned solely from the product label or generic agreement. |
S015; S016 majority pp.5–7. |
Conditional; Gemini unpublished. |
| S_IA-P8-C007 |
A continuous open current account accrues at its last qualifying item proved at trial. |
S001 §614.5; S018 pp.435–436. |
High; unilateral entry may not qualify. |
| S_IA-P8-C008 |
Account stated is a possible theory, not proof of a new limitations period. |
S017 printed pp.11–18. |
Holding concerns proof; barred-debt replacement question unresolved. |
| S_IA-P8-C009 |
Iowa Article3 time/demand instrument accrual follows §554.3118, not an imported uniform six-year provision. |
S004 §554.3118(1). |
High; instrument/party qualification required. |
| S_IA-P8-C010 |
Installments can accrue separately absent effective acceleration. |
S022 pp.158–160. |
High doctrine; actual schedule absent. |
| S_IA-P8-C011 |
Optional acceleration requires operative exercise and may be waived by conduct. |
S022 §VI; S023 §§I–II. |
Conditional; automatic-clause construction not universal. |
| S_IA-P8-C012 |
Covered consumer-credit enforcement must satisfy applicable default/cure conditions before acceleration or action. |
S005 §§537.5102,.5109,.5110. |
High text; transaction coverage and valid notice unproved. |
| S_IA-P8-C013 |
Charge-off, demand, collection placement, or sale is not a universal accrual trigger. |
S001 §§614.1,.5; S004; S022. |
Inference from specified triggers; actual contract needed. |
| S_IA-P8-C014 |
Section614.11 requires a signed written unpaid-debt admission or like new promise. |
S001 §614.11. |
High; content, party, signature, and debt identity required. |
| S_IA-P8-C015 |
Bare partial payment or oral promise does not itself establish statutory revival. |
S019 §IV; S021 §IX. |
High; accompanying qualifying writing may change result. |
| S_IA-P8-C016 |
Claimant must prove the written acknowledgment relates to the debt; ambiguous entries can fail. |
S020 pp.21–23; S021 pp.866–867. |
High; preponderance in Schroedl, actual evidence absent. |
| S_IA-P8-C017 |
Representative/co-obligor conduct is not automatically the acknowledgment of every party charged. |
S001 §614.11; S018. |
Conditional; agency/authorization law not exhaustively researched. |
| S_IA-P8-C018 |
Revival can concern an otherwise barred contract; resulting trigger depends on the qualifying acknowledgment/promise and claim. |
S001 §614.11; S020–S021. |
High gateway; conditional/new-promise and oral-debt period questions held. |
| S_IA-P8-C019 |
Outside the UCC, assignment preserves the defenses specified in Rule1.205; acquisition price is not debtor payment. |
S006 Rule1.205; S001 §614.11. |
High text/inference; ownership and UCC status unproved. |
| S_IA-P8-C020 |
Iowa forum limitation and §614.7 borrowing require distinct analysis. |
S024 pp.596–598; S001 §614.7. |
High; foreign complete bar/residency/non-Iowa origin unproved. |
| S_IA-P8-C021 |
A choice clause or foreign period alone does not settle procedural/substantive classification. |
S024; S001 §614.7. |
Conditional; actual clause and foreign law missing. |
| S_IA-P8-C022 |
Section614.8 protects specified claimants through its disability/minority extension. |
S001 §614.8(1)–(2). |
High; not automatic tolling from debtor illness. |
| S_IA-P8-C023 |
Nonresidence and unknown-person provisions are conditional; service amenability matters under Kokenge. |
S001 §614.6; S025 pp.711–713. |
High text/historical holding; modern application unresolved. |
| S_IA-P8-C024 |
Discovery/accrual, statutory tolling, and concealment estoppel are distinct doctrines. |
S001 §614.4; S026 §III. |
High distinction; ordinary-debt and2026-act application qualified. |
| S_IA-P8-C025 |
A qualifying prohibition on commencement excludes its duration under §614.13, subject to chapter exceptions. |
S001 §614.13. |
High; order/statute and dates missing. |
| S_IA-P8-C026 |
Bankruptcy extension, discharge, reaffirmation, and voluntary repayment must be separately tested. |
S013 §§108(c),524(a),(c),(e)–(f). |
High gateway; no actual bankruptcy facts. |
| S_IA-P8-C027 |
SCRA §3936 excludes qualifying military-service time, with stated exceptions. |
S014 §3936(a)–(c). |
High; status/dates and state-only service held. |
| S_IA-P8-C028 |
Regular action commencement uses petition filing; small claims uses original-notice filing. |
S006 Rule1.301; S031 §631.3. |
High; forum and later service requirements separate. |
| S_IA-P8-C029 |
Ninety-day service rule includes dismissal/alternative-direction and good-cause branches. |
S006 Rule1.302(5); S029 pp.5–15. |
High; not a guaranteed extension. |
| S_IA-P8-C030 |
Section614.10 supplies six-month continuation only after qualifying nonnegligent failure. |
S001 §614.10; S027–S028. |
High; reason/date of failure indispensable. |
| S_IA-P8-C031 |
Relation back has occurrence and additional changed-party conditions. |
S006 Rule1.402(5). |
High; no automatic correction of wrong defendant. |
| S_IA-P8-C032 |
Calendar and terminal-day rules must be applied to the particular period. |
S003 §4.1(16),(34),(40); S006 Rule1.1801. |
High; actual closure/holiday and fixed-lien duration issues separate. |
| S_IA-P8-C033 |
Ordinary court-of-record judgment actions have a twenty-year statutory category. |
S001 §614.1(6). |
High; express support/marital and special-statute exceptions. |
| S_IA-P8-C034 |
Non-record judgments have a different ten-year category. |
S001 §614.1(5)(a). |
High; actual court classification required. |
| S_IA-P8-C035 |
Early action on an Iowa record judgment within nine years requires statutory leave/notice; those years are not excluded. |
S001 §614.3. |
High; historical justice-of-peace clause not generalized. |
| S_IA-P8-C036 |
Ordinary judgment lien duration and county attachment are governed separately by §§624.23–.24. |
S008 §§624.23(1),624.24. |
High; no property/priority conclusion. |
| S_IA-P8-C037 |
A motion alone does not extend the original lien; separate judgment action is the recognized route. |
S030 §II. |
High narrow holding; entitlement to new judgment unproved. |
| S_IA-P8-C038 |
Judgment enforcement, individual execution return, and continuing garnishment are different timing questions. |
S009 §§626.2,.16,.27. |
High text; 120-day return is not judgment duration. |
| S_IA-P8-C039 |
Assigned-for-value rent judgments can trigger §615.1A’s special two-year rule. |
S010 §615.1A. |
High current compilation; actual actor/stays and historical application held. |
| S_IA-P8-C040 |
Full satisfaction requires the statutory acknowledgment/filing process; it is not mere lapse of time. |
S008 §624.37. |
High; balance, recipient, filings, and remedy facts absent. |
| S_IA-P8-C041 |
Covered debt collectors may not bring/threaten time-barred legal action, subject to the bankruptcy-proof exception. |
S011 §1006.26. |
High; actual actor/debt coverage unproved. |
| S_IA-P8-C042 |
FCRA reporting clocks differ from state claim/judgment clocks and have statutory exceptions. |
S012 §1681c(a),(b),(c). |
High; actual reporting practices and delinquency facts absent. |
| S_IA-P8-C043 |
Limitations proof does not establish underlying debt validity; defensive avoidance and revival have separate pleading/proof burdens. |
S006 Rule1.419; S015; S021; S013 §524. |
High distinction; no actual obligation adjudicated. |
| S_IA-P8-C044 |
Iowa goods limitations refer to chapter614 and contain separate reduction/accrual/savings conditions. |
S004 §554.2725(1)–(4). |
High; no imported four-year period. |
| S_IA-P8-C045 |
Installment small-claims judgments have compliance/default-affidavit enforcement conditions. |
S031 §631.12(1). |
High; does not create a fresh judgment period. |
| S_IA-P8-C046 |
Gemini is unpublished and usable only within the applicable noncontrolling-reasoning citation rule. |
S007 Rule6.904(2)(a)(2); S016. |
High for retrieved rule; no filing prepared. |
| S_IA-P8-C047 |
This pass verifies selected current texts and one2026 amendment, not every later law, transition, or negative-treatment event. |
Source-version/read records. |
Confirmed research limitation. |
| S_IA-P8-C048 |
Section614.12 permits only its conditional defensive use of an otherwise barred counterclaim, not ordinary affirmative recovery. |
S001 §614.12. |
High; ownership/timing predicates and actual pleading absent. |
I. Complete component coverage reconciliation
Status meaning: “Answered” means the identified general text or narrow holding is supported—not that any actual account is classified. “Partial” means material doctrine is established but an identified legal or factual issue remains. “Unresolved” is not an adverse conclusion. Exclusions remain required later work.
| Coverage ID / requested issue |
Status |
Claims |
Exact missing evidence or next investigation |
| CV01 — Current periods and2026 amendment |
Answered with currentness limit |
C001–C003,C047 |
Complete other-enactment audit and post-amendment construction. |
| CV02 — Written-contract category |
Partial |
C003–C004 |
Authentic obligation, complete terms, applicable published-case comparison. |
| CV03 — Unsigned/electronic classification |
Partial |
C005–C006 |
Assent, attribution, incorporation, UCC scope and actual record. |
| CV04 — Card/open-account distinction |
Partial |
C006–C007 |
Actual claim theory and transaction history; modern controlling card-SOL opinion not located. |
| CV05 — Account stated |
Partial |
C008 |
Actual assent and a responsive holding on limitation/revival of an already barred account. |
| CV06 — Notes/demand/time instruments |
Answered conditionally |
C009 |
Instrument status, maturity and special instrument provisions. |
| CV07 — Separate installments |
Answered conditionally |
C010 |
Actual schedule and maturity events. |
| CV08 — Optional/automatic acceleration and cure |
Partial |
C011–C012 |
Authentic clause, election, waiver, valid notice, coverage; no universal automatic-clause rule. |
| CV09 — Charge-off/first-miss/sale accrual |
Answered as nonautomatic |
C013 |
Actual legally operative trigger. |
| CV10 — Validity and burdens |
Partial |
C016,C043 |
Actual debt, identity, defenses, summary-judgment record; full merits excluded. |
| CV11 — Written acknowledgment/new promise |
Answered at gateway |
C014,C016 |
Actual signed content and identified debt. |
| CV12 — Before/after expiry and resulting duration |
Partial |
C018 |
Conditional promises, novations, oral-debt conversion, exact revival date. |
| CV13 — Partial/interest/token payment |
Answered as insufficient alone |
C015 |
Associated signed admission/promise, if any. |
| CV14 — Attorney/agent/co-obligor/representative acts |
Partial |
C017,C026 |
Authority, each party charged, insolvency/estate law where relevant. |
| CV15 — Sale and assignee rights |
Partial |
C019,C039 |
Chain of title, UCC status, rent-judgment exception, actual transfer terms. |
| CV16 — Forum law/borrowing |
Partial |
C020 |
Cause location, prior residence, complete foreign bar. |
| CV17 — Choice clauses/foreign substantive law |
Unresolved for actual transaction |
C021 |
Clause and foreign statute/cases; no shortest/longest shortcut. |
| CV18 — Disability/minority |
Answered conditionally |
C022 |
Protected claimant, disability and termination dates, exceptions. |
| CV19 — Absence/nonresidence/unknown identity |
Partial |
C023 |
Modern service amenability and actual statutory eligibility. |
| CV20 — Discovery/concealment/estoppel |
Partial |
C024,C001 |
Ordinary-debt facts, proof elements, post2026 construction. |
| CV21 — Statutory/injunction tolling |
Answered conditionally |
C025 |
Actual prohibition and dates; chapter exceptions. |
| CV22 — Bankruptcy boundary |
Partial |
C026 |
Stay/discharge/reaffirmation orders and governing suspension law. |
| CV23 — Military boundary |
Partial |
C027 |
Service status/dates; Iowa §29A.98 and state-only service remain open. |
| CV24 — Savings/dismissal/recommencement |
Answered conditionally |
C030,C044 |
Reason/date of failure; distinguish goods savings provision. |
| CV25 — Commencement to stop clock |
Answered by forum category |
C028 |
Actual filing; federal/other-forum commencement excluded. |
| CV26 — Service preservation |
Partial |
C029 |
Actual service, good cause, extension, court direction; no answer/default analysis. |
| CV27 — Relation back |
Answered conditionally |
C031 |
Same occurrence, notice, prejudice, identity mistake. |
| CV28 — Counting/weekends/holidays |
Answered for stipulated models |
C032 |
Actual clerk closure and future-law verification; fixed-lien issue qualified. |
| CV29 — Court-of-record judgment duration |
Answered conditionally |
C033 |
Actual court/category/date, stays, satisfaction, special statutes. |
| CV30 — Non-record/small-claims distinction |
Partial |
C034,C045 |
Actual tribunal status and installment order; not all small claims deemed non-record. |
| CV31 — Action on judgment/early leave |
Answered |
C035 |
Actual creditor entitlement, petition, notice and order. |
| CV32 — Lien duration/recording |
Answered at gateway |
C036 |
Property, county filings, exemptions and priority excluded. |
| CV33 — New judgment versus motion renewal |
Answered at mechanism level |
C037 |
Actual new action/judgment; no automatic entitlement. |
| CV34 — Dormancy/individual writ/continuing process |
Partial |
C038 |
No extra universal dormancy period established; special process facts and exceptions remain. |
| CV35 — Changed judgment ownership/special rent |
Partial |
C019,C039 |
Transfer facts and2013/2018 application history. |
| CV36 — Satisfaction/release |
Answered at gateway |
C040 |
Actual payoff, instrument, county entries; full remedies/interest model excluded. |
| CV37 — Federal time-barred-suit overlay |
Answered conditionally |
C041 |
Actual FDCPA/RegulationF actor and debt coverage. |
| CV38 — Reporting clock separation |
Answered conditionally |
C042 |
Delinquency/cure history, statutory exceptions; complete FCRA excluded. |
| CV39 — Defensive counterclaim |
Answered conditionally |
C048 |
Statutory ownership and timing; no affirmative recovery inferred. |
| CV40 — Published cases and unpublished status |
Answered with citator limit |
C046–C047 |
Complete later-treatment review, reporter citations not verified for specified rows. |
| CV41 — Four models and22 smaller postures |
Completed as fictional analysis |
Relevant claims above |
No actual client facts; conditional results cannot be operationalized. |
| CV42 — Federal court/local/tribal/international |
Excluded except boundaries |
C020,C027,C036,C047 |
Forum-specific commencement, recognition, jurisdiction and tribal law. |
| CV43 — Special sectors and broader merits |
Excluded except necessary distinctions |
C003,C012,C026,C039,C044 |
Secured debt, tax, support, education, estates, garnishment, exemptions and full litigation. |
| CV44 — Actual-account/currentness/acceptance limits |
Unresolved |
C043,C047 |
No actual obligation, payment, assignment, judgment, service or account; no complete later-law/citator certificate. |
J. Scope and contribution crosswalk
| Authorized remainder |
PASS-08 contribution |
What remains open |
| Ordinary limitation, accrual, acknowledgment, payment, sale |
Classification framework, current statutory periods, revival distinctions, responsive cases, conditional models. |
Actual agreement classification, foreign law, agency attribution, conditional promises and unresolved modern interpretations. |
| Judgment duration/renewal distinction |
Twenty-year action framework, nine-year early-action restriction, ten-year lien, separate-action mechanism, execution-return distinction, rent-assignment exception. |
Actual judgment, ownership, remaining balance, lien priority, foreign recognition, full enforcement, satisfaction remedies and interest. |
| Collection/court/limitations parent |
Only commencement/service preservation, savings, relation back, and narrow federal boundaries necessary to this component. |
General service, answer/default/vacatur, evidentiary merits, standing proof, litigation procedures, garnishment and exemptions. |
| Prior provider/funds/bond/agreement work |
Preserved at its original reviewed or unreviewed status. No P04/P06 premise imported; no P07 surety-service deadline generalized. |
All prior currentness, ARC0368D, records, provider, contract, funds, bond, local/tribal/sector and seven-parent-dimension holds. |
The crosswalk is a scope record, not additional accepted coverage.
K. Researcher self-check and exact residual evidence gaps
Actual work performed
The public-law research freshly opened operative Iowa statutes, the relevant 2026 enacted amendment and official bill history, selected court-rule bodies, federal statutory/regulatory provisions, and the majority bodies identified in the case matrix.
Selected PDF pages were visually inspected, including the limitation provisions, enacted amendment, Iowa UCC sections, consumer-credit cure provisions, civil/appellate rules, judgment and execution provisions, small-claims sections, narrow electronic-record provisions, and the relevant pages of the available opinion PDFs. This does not claim visual inspection of every page of every chapter or opinion.
The four models were separately calculated using calendar-date arithmetic. No prior fee, funds, bond, or agreement example was rerun.
Failed or limited routes
These failures are preserved as route limitations, not evidence that the law is absent.
Remaining legal research gaps
The most consequential unresolved legal issues are:
- A modern controlling Iowa majority decision squarely classifying the full range of current credit-card/electronic-account records for §614.1 purposes.
- The limitation consequences of a genuinely new, conditional promise or account-stated agreement after an earlier claim has become barred.
- Modern ordinary-debt application of nonresidence tolling where the defendant remains amenable to service.
- Full construction of the July1,2026 amendment in pending/pre-effective cases and disputed equitable-extension settings.
- Actual foreign-law, contractual-choice, substantive-repose, and borrowing predicates.
- Complete historical application of special rent-judgment amendments and other special judgment statutes.
- Complete later court-rule and citator checks beyond the selected official bodies and bounded order review.
No source gap was filled with a guessed period, invented holding, assumed account document, or fabricated filing date.
What was not done
No actual borrower, creditor, provider, property, payment, account, assignment, judgment, court term, docket, or case-status record was searched. Published opinions were accessed as public legal authorities, not as investigations of their parties.
No filing, service, collection, reporting, payment, account change, contact, private-record request, browser control, local write, publication, or cross-chat action occurred. No hash verification, independent review, whole-state certification, full citator audit, or unseen-source verification is claimed.
Disposition: The requested limitation and judgment-duration component has substantive, sourced findings and explicit unresolved boundaries. It does not establish a safe payment date, filing date, valid debt, collectible judgment, provider permission, component acceptance, Iowa acceptance, parent acceptance, A066/A097/A098 acceptance, operational approval, or publication readiness.
END S_IA PASS-08