Chad Michael Reed v. Dean Edward Anderson

Summary

The Iowa Court of Appeals affirmed a district court order interpreting a prior specific-performance judgment concerning the sale of farmland. The court held that the buyer owed only the remaining purchase-price balance and that the seller could not treat the buyer's continued use of the property as cash rent or deduct it from the earnest-money payment. The court also held that the seller failed to preserve claims for interest and property-tax reimbursement by raising them for the first time in a posttrial motion.

Holdings

1. The prior order did not permit Anderson to deduct annual rent from Reed's $50,000 earnest-money payment or to increase the amount Reed had to pay to complete the sale. The only remaining purchase-price balance was $115,200.
2. Anderson failed to preserve his claims for interest and property-tax reimbursement because he raised them for the first time in a Rule 1.904(2) posttrial motion.

Questions Presented

1. Whether the 2020 specific-performance order and its reference to an amortization exhibit allowed Anderson to deduct annual cash rent from Reed's $50,000 earnest-money payment and require Reed to pay the deducted amount again toward the purchase price.
2. Whether Anderson preserved his claims for interest on the unpaid purchase-price balance and reimbursement of property taxes by raising them for the first time in a Rule 1.904(2) posttrial motion.

Disposition

affirmed