In 2024, an Iowa court let a farmer keep the family land his father had transferred to him, despite his siblings’ challenge

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. In 2024, the Iowa Court of Appeals decided Natvig v. Natvig, a dispute over a family farm. In its opinion No. 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. 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 Natvig’s transfers of 160 acres to MichaelGodfrey 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. 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. In early 2016, Godfrey conveyed the remaining 80 acres to Michael by warranty deed, bringing the total transferred to Michael to 160 acres.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. These details come from the Iowa Court of Appeals’ opinion.Siblings challenged the transfer and estate plansGodfrey’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 argued that Godfrey wrongly believed his children planned to sell the 80 acres after his death. 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.In early 2017, the siblings asked a court to remove Michael as Godfrey’s attorney-in-fact, alleging breach of fiduciary duty. Godfrey intervened and testified and the district court found that he had the capacity to revoke Michael’s power of attorney if he chose to. It dismissed the petition. Godfrey died in 2018 and Michael became executor of his estate. In 2019, the siblings filed a new action alleging that the 2016 codicil was procured by undue influence and that Michael obtained the 80-acre deed while acting as Godfrey’s attorney-in-fact. At a three-day trial, the district court heard from Michael, six of his siblings, Godfrey’s attorney, physician, tax preparer and caregiver and other witnesses. The court dismissed the siblings’ petition and they appealed.Independent legal advice supported the transferThe question was whether Michael had improperly influenced his father or whether Godfrey had voluntarily chosen to transfer the land. Because Michael and Godfrey were in a confidential relationship, which Michael did not dispute, Iowa law presumed the transfer was the product of undue influence. Michael therefore had to rebut the presumption with clear, convincing and satisfactory evidence that he acted in good faith and that Godfrey gave the land freely, intelligently and voluntarily. Iowa law treats proper independent advice as one way to show a grantor acted freely, so the court weighed evidence that Godfrey had the benefit of such advice before the transfer. Godfrey’s physician had also evaluated Godfrey’s ability to manage legal transactions. In January 2016, Dr. Paul Jensen concluded that Godfrey was capable of understanding the ramifications of the decisions and changes he might need to make.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 Iowa Court of Appeals affirmed on 30 October 2024The court of appeals affirmed the district court’s dismissal, leaving the farmland transfer and Godfrey’s estate plan intact. 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. 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 case highlights the importance of documenting estate decisionsThe 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.You use AI every day. Now get your AI Quotient. Take the AIQ test.