Iowa Supreme Court: Tortious Interference With An Inheritance Action Barred Unless Joined With A Timely Will Contest

In Youngblut v. Youngblut, the Iowa Supreme Court considered its first tortious interference with an inheritance case in almost 30 years, overruling its prior decisions and holding that a claim alleging that a decedent’s will resulted from tortious interference by a beneficiary must be joined with a timely will contest; otherwise, it is barred.

Harold and Leonard Youngblut are brothers. Their parents, Earl and Agnes Youngblut, were successful farmers, who formed Youngblut Farmland Ltd. (YFL) in 1980. Both parents died in 2014 and a dispute arose between the two brothers concerning Earl and Agnes’ mirror wills. 

The mirror wills provided that Harold would receive his parents’ YFL shares and the South Farm would go to Leonard so long as he tendered his YFL stock to Harold for one dollar. The 2014 mirror wills were probated. 

The statutory deadline under Iowa law to file a will contest was October 20 and Harold decided not to file a will contest. Days after Leonard tendered his YFL shares to Harold, Harold sued Leonard for tortious interference with an inheritance in Iowa District Court. 

Here, Harold essentially used a tortious interference claim as a substitute for a will contest based on undue influence. 

The Iowa Supreme Court held that a party alleging a decedent’s will was procured in whole or in part by tortious interference must join a claim together with a timely will contest under Iowa Code section 633.308. 

See, Iowa Supreme Court: Tortious Interference With An Inheritance Action Barred Unless Joined With A Timely Will Contest, Probate Stars, June 15, 2020.