Supreme Court of Iowa

Dupaco Community Credit Union v. Iowa District Court for Linn County

November 8, 2024

Summary

The court vacated the court of appeals decision, sustained the writ of certiorari, vacated sanctions against the credit union and its attorneys, and remanded. It held that the sanctions rule evaluates the signer’s objectively reasonable conduct when the paper was filed, not later developments or conduct at subsequent hearings. Under that standard, the investigation supporting the filing was reasonable despite factual mistakes, and the rule did not authorize sanctions against an attorney for later oral advocacy or failure to correct the filing.