Supreme Court of Iowa

Lisa Boggess, as administrator of the Estate of Brent Boggess, and as next friend to minors Z.B. and J.B., Drake L…

May 1, 2026

Summary

The Iowa Supreme Court reversed the district court’s summary‑judgment dismissal, holding that Iowa Code §670.4A does not extend qualified immunity to common‑law tort claims such as assault and battery and that the district court improperly applied issue preclusion based on the federal Harlow decision because the issues were not identical. The court reinstated the plaintiffs’ assault, battery, and statutory use‑of‑force claims for further proceedings.