Henningsen v. Eastern Iowa Propane, Ltd.

Summary

The Iowa Supreme Court held that Iowa Code section 614.1(11), governing claims arising from unsafe or defective improvements to real property, applied to a propane furnace gas valve attached to a residence. The court concluded that the fifteen-year repose period began when Honeywell manufactured the valve, not when it was installed, and that section 614.1(2A) did not apply to the case. The court also rejected an equal-protection challenge and affirmed summary judgment for Honeywell.

Holdings

1. Iowa Code section 614.1(11), rather than section 614.1(2A), governs claims involving a product attached to real property and covered as an improvement to real property. Section 614.1(2A) is inapplicable to cases governed by section 614.1(11), including contribution and indemnity claims.
2. The fifteen-year repose period began when Honeywell manufactured the gas valve in 1968, not when the valve was installed in the furnace.
3. Iowa Code section 614.1(11) does not deny claimants equal protection under the Iowa Constitution.

Questions Presented

1. Whether Iowa Code section 614.1(11), governing actions arising from the unsafe or defective condition of improvements to real property, or Iowa Code section 614.1(2A), governing products-liability actions and containing an exception for contribution or indemnity claims, applied to Eastern Iowa Propane's claims against Honeywell.
2. If section 614.1(11) applied, whether the fifteen-year repose period began when the valve was installed or when Honeywell manufactured it.
3. Whether Iowa Code section 614.1(11) violated the equal-protection guarantee of the Iowa Constitution.

Disposition

affirmed