Most Recent Opinions

Summaries for Most Recent Opinions

Click here for summaries of selected opinions most recently filed by the Iowa Court of Appeals.

 

Opinions of the Iowa Court of Appeals will be filed at 10:00 a.m. on the dates listed below:

2014

 

 

 

January 9

April 30

August 13

November 26

January 23

May 14

August 27

December 10

February 5

May 29

September 17

December 24

February 19

June 11

October 1

 

March 12

June 25

October 15

 

March 26

July 16

October 29

 

April 16

July 30

November 13

 

 

 

 

 

For your convenience, the Judicial Branch offers a free e-mail notification service for supreme court opinions, court of appeals opinions, press releases and orders.

Opinions Expected Next Filing Date

A list of cases on which the Iowa Court of Appeals is expected to rule will be posted at 10:00 a.m. one day preceding each opinion filing day.

 

Opinions Archive

This archive contains opinions from 1998 to the present. Summaries of opinions are archived for opinions filed between 1998 to April 12, 2006 only.

Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read:  Using the Adobe Reader.

Notice: The opinions posted on this site are slip opinions only. Under the Rules of Appellate Procedure a party has a limited number of days to request a rehearing after the filing of an opinion. Also, all slip opinions are subject to modification or correction by the court. Therefore, opinions on this site are not to be considered the final decisions of the court. The official published opinions of the Iowa Supreme Court are those published in the North Western Reporter published by West Group.
Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read: Using the Adobe Reader.
For your convenience, the Judicial Branch offers a free e-mail notification service for Supreme Court opinions, Court of Appeals opinions, press releases and orders. To subscribe, click here.
NOTE: Copies of these opinions may be obtained from the Clerk of the Supreme Court, Judicial Branch Building, 1111 East Court Avenue, Des Moines, IA 50319, for a fee of fifty cents per page.
No. 13-0417
MAXINE GAIL VEATCH vs. CITY OF WAVERLY and JASON LEONARD, individually and in his official capacity
No. 13-0702
STATE OF IOWA vs. BEAU JACKSON MORRIS
No. 13-1106
STATE OF IOWA vs. CARRIE McIVER
No. 13-1113
STATE OF IOWA vs. JILLIAN JANE STEWART
Notice: The opinions posted on this site are slip opinions only. Under the Rules of Appellate Procedure a party has a limited number of days to request a rehearing after the filing of an opinion. Also, all slip opinions are subject to modification or correction by the court. Therefore, opinions on this site are not to be considered the final decisions of the court. The official published opinions of the Iowa Supreme Court are those published in the North Western Reporter published by West Group.
Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read: Using the Adobe Reader.
For your convenience, the Judicial Branch offers a free e-mail notification service for Supreme Court opinions, Court of Appeals opinions, press releases and orders. To subscribe, click here.
NOTE: Copies of these opinions may be obtained from the Clerk of the Supreme Court, Judicial Branch Building, 1111 East Court Avenue, Des Moines, IA 50319, for a fee of fifty cents per page.
No. 14-0288
IN THE INTEREST OF J.C, Minor Child. D.C., Father
No. 14-1406
IOWA SUPREME COURT ATTORNEY DISCIPLINARY BOARD vs. ROBERT ALLAN WRIGHT JR.

GRANTED:

 

NUMBER

COUNTY

CASE NAME

 

 

 

13-0917

Polk

State v. Galarza

13-2044

Linn

In re Marriage of Thatcher

14-0374

Polk

State v. Thacker

 

DENIED:

NUMBER

COUNTY

CASE NAME

 

12-2241

Polk

Nelson v. State

13-0332

Clayton

Aschliman v. Hettinger

13-0358

Boone

Blair v. State

13-0487

Polk

State v. McLachlan

13-0814

Polk

Crabb v. Iowa Dist. Ct.

13-0991

Johnson

State v. Cox

13-1036

Clayton

Koehn v. Koehn Bros. Farms

13-1099

Polk

State v. Davis

13-1111

Cerro Gordo

State v. Manning

13-1112

Pok

State v. Nelson

13-1128

Polk

Bell v. State

13-1143

Polk

State v. Galbo

13-1231

Scott

State v. Weeks

13-1378

Polk

Richardson v. State

13-1402

Des Moines

State v. Phillips

13-1422

Osceola

Mohr v. Mohr

13-1505

Polk

Burn v. Sinclair

13-1637

Scott

State v. Johnson

13-1748

Polk

Mercy Hosp, IC v. Goodner

13-1878

Clinton

In re Marriage of McManus

13-1887

Linn

Spencer v. Philipp

13-1893

Scott

State v. Garza

13-1894

Jackson

State v. Laufenberg

14-0052

Polk

State v. Avery

14-0094

Polk

Drysdale v. Abbott

14-0249

Marshall

State v. Doty

14-0389

Scott

State v. Thompson

14-0393

Black Hawk

State v. Raymond

14-1018

Cerro Gordo

In re A.R.

14-1516

Polk

In re G.B.

14-1644

Clinton

In re B.G.

 

 

UNDER CONSIDERATION BY THE COURT:

NUMBER

COUNTY

CASE NAME

 

13-1094

State v. Twigg

13-1506

UPS v. EAB

13-1837

State v. Winfrey

13-0863

Wyngarden v. State

13-0712

State v. Wilson

13-1147

State v. Powell

13-1577

State v. Goodwin

13-1938

State v. Lyon

14-0231

DART v. Young

Summaries for Most Recent Opinions

Click here for summaries of selected opinions most recently filed by the Iowa Court of Appeals.

 

Opinions of the Iowa Court of Appeals will be filed at 10:00 a.m. on the dates listed below:

2014

 

 

 

January 9

April 30

August 13

November 26

January 23

May 14

August 27

December 10

February 5

May 29

September 17

December 24

February 19

June 11

October 1

 

March 12

June 25

October 15

 

March 26

July 16

October 29

 

April 16

July 30

November 13

 

 

 

 

 

For your convenience, the Judicial Branch offers a free e-mail notification service for supreme court opinions, court of appeals opinions, press releases and orders.

Opinions Expected Next Filing Date

A list of cases on which the Iowa Court of Appeals is expected to rule will be posted at 10:00 a.m. one day preceding each opinion filing day.

 

Opinions Archive

This archive contains opinions from 1998 to the present. Summaries of opinions are archived for opinions filed between 1998 to April 12, 2006 only.

Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read:  Using the Adobe Reader.

Notice: The opinions posted on this site are slip opinions only. Under the Rules of Appellate Procedure a party has a limited number of days to request a rehearing after the filing of an opinion. Also, all slip opinions are subject to modification or correction by the court. Therefore, opinions on this site are not to be considered the final decisions of the court. The official published opinions of the Iowa Supreme Court are those published in the North Western Reporter published by West Group.
Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read: Using the Adobe Reader.
For your convenience, the Judicial Branch offers a free e-mail notification service for Supreme Court opinions, Court of Appeals opinions, press releases and orders. To subscribe, click here.
NOTE: Copies of these opinions may be obtained from the Clerk of the Supreme Court, Judicial Branch Building, 1111 East Court Avenue, Des Moines, IA 50319, for a fee of fifty cents per page.
No. 13-0925
COURTNEY M. KAY-DECKER, Director, Iowa Department of Revenue vs. IOWA STATE BOARD OF TAX REVIEW and CABLE ONE, INC.
No. 13-1636
NORTHEAST COMMUNITY SCHOOL DISTRICT vs. EASTON VALLEY COMMUNITY SCHOOL DISTRICT
No. 13-1808
DENISON MUNICIPAL UTILITIES vs. IOWA WORKERS' COMPENSATION COMMISSIONER
No. 13-1895
STATE OF IOWA vs. WARREN WILLIAM LOVELL
Notice: The opinions posted on this site are slip opinions only. Under the Rules of Appellate Procedure a party has a limited number of days to request a rehearing after the filing of an opinion. Also, all slip opinions are subject to modification or correction by the court. Therefore, opinions on this site are not to be considered the final decisions of the court. The official published opinions of the Iowa Supreme Court are those published in the North Western Reporter published by West Group.
Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read: Using the Adobe Reader.
For your convenience, the Judicial Branch offers a free e-mail notification service for Supreme Court opinions, Court of Appeals opinions, press releases and orders. To subscribe, click here.
NOTE: Copies of these opinions may be obtained from the Clerk of the Supreme Court, Judicial Branch Building, 1111 East Court Avenue, Des Moines, IA 50319, for a fee of fifty cents per page.
No. 13-0060
LUANA SAVINGS BANK vs. PRO-BUILD HOLDINGS, INC. and UNITED BUILDING CENTERS
No. 13-1285
ROSAUER CORPORATION vs. SAPP DEVELOPMENT, L.L.C.; TODD SAPP; WHISPERING CREEK, L.L.C.; and W.C. DEVELOPMENT, INC.
No. 13-1764
STATE OF IOWA vs. MARK AARON THOMPSON
No. 14-0944
IOWA SUPREME COURT ATTORNEY DISCIPLINARY BOARD vs. SETH EUGENE BALDWIN
Notice: The opinions posted on this site are slip opinions only. Under the Rules of Appellate Procedure a party has a limited number of days to request a rehearing after the filing of an opinion. Also, all slip opinions are subject to modification or correction by the court. Therefore, opinions on this site are not to be considered the final decisions of the court. The official published opinions of the Iowa Supreme Court are those published in the North Western Reporter published by West Group.
Opinions released before April 2006 and available in the archives are posted in Word format. Opinions released after April 2006 are posted to the website in PDF (Portable Document Format).   Note: To open a PDF you must have the free Acrobat Reader installed. PDF format preserves the original appearance of a document without requiring you to possess the software that created that document. For more information about PDF read: Using the Adobe Reader.
For your convenience, the Judicial Branch offers a free e-mail notification service for Supreme Court opinions, Court of Appeals opinions, press releases and orders. To subscribe, click here.
NOTE: Copies of these opinions may be obtained from the Clerk of the Supreme Court, Judicial Branch Building, 1111 East Court Avenue, Des Moines, IA 50319, for a fee of fifty cents per page.
No. 12-0729
STATE OF IOWA vs. PATRICK MICHAEL DUDLEY
No. 12-1633
STATE OF IOWA vs. MATTHEW EUGENE BROWN
No. 12-2264
STATE OF IOWA vs. JOSE FERNANDO JAQUEZ SR.
Adoption of New and Amended Rules Governing Court Interpreters (December 4, 2014)
Chapters 47 and 48 of the Iowa Court Rules
Effective July 1, 2015
Order (177 kb)
Chapter 47 (326 kb)
Chapter 48 (219 kb)
Revisions to Expedited Civil Action Rule and Recent Amendments to Iowa Discovery Rules (October 30, 2014)
Order (92 kb)
Rule 1.281 expedited civil changes (27 kb)
Rule 1.500 Discovery changes (65 kb)
Joint Motion to Proceed as an Expedited Civil Action: Rule 1.1901–Form 18 (18 kb)
Notice of Civil Trial-Setting Conference: Rule 23.5–Form 1 (40 kb)
Trial Scheduling and Discovery Plan: Rule 23.5–Form 2 (74 kb)
Trial Scheduling and Discovery Plan for Expedited Civil Action: Rule 23.5–Form 3 (71 kb)
Adoption of Expedited Civil Action Rule and Amendments to Iowa Discovery Rules (August 28, 2014)
Order (1195 kb)
Ch. 1 Expedited Civil Action Rule 1.281 (300 kb)
Ch. 1 Discovery Amendments (439 kb)
Expedited Civil Action Certification: Rule 1.1901--Form 16 (220 kb)
Expedited Civil Action Certification: Rule 1.1901--Form 17 (221 kb)
Joint Motion to Proceed as an Expedited Civil Action: Rule 1.1901–Form 18 (176 kb)
Health Care Provider Statement in Lieu of Testimony: Rule 1.1901–Form 19 (238 kb)
Ch. 23 Time Standards for Case Processing (220 kb)
Notice of Civil Trial-Setting Conference: Rule 23.5–Form 1 (208 kb)
Trial Scheduling Order and Discovery Plan: Rule 23.5–Form 2 (310 kb)
Trial Scheduling Order and Discovery Plan for Expedited Civil Action: Rule 23.5–Form 3 (312 kb)
In the Matter of Interim Rules to Govern the use of the Electronic Document Management System (August 15, 2014)
Order (80 kb)
In the Matter of Probate Forms in Chapter 7 of the Iowa Court Rules (June 17, 2014)
Amended forms to take effect permanently August 16, 2014
Order (43 kb)
In the Matter of Probate Forms in Chapter 7 of the Iowa Court Rules (May 23, 2014)
Order (53 kb)
Chapter 7 Title and Contents (140 kb)
Probate Forms (286 kb)
In the Matter of Chapter 25 of the Iowa Court Rules (April 29, 2014)
Further amendments to rules and forms of Chapter 25
Effective May 1, 2014
Order (43 kb)
Chapter 25, Rules for Expanded News Media Coverage (246 kb)
Chapter 25, EMNC forms (562 kb)
Summary of Amendments to Chapter 25 (203 kb)
In the Matter of Amendments to Division III of the Iowa Court Rules (April 25, 2014)
Order (45 kb)
Rule Changes for Law Student Registration & Lawyer Reporting Dates (98 kb)
In the Matter of Chapter 25 of the Iowa Court Rules (April 2, 2014)
Effective May 1, 2014
Order (115 kb)
Chapter 25, Rules for Expanded News Media Coverage (245 kb)
Chapter 25, EMNC forms (512 kb)
Summary of Amendments to Chapter 25 (201 kb)
In the Matter of Chapter 17 of the Iowa Court Rules and Self Represented Litigant Forms for Disestablishing Legal Parent (March 26, 20140
Order (73 kb)
Rule 17.200 Family law forms for dissolution of marriage with dependent children (129 kb)
Form 212: Joint Statement on Legal Parent (501 kb)
Form 213: Motion to Disestablish Legal Parent (504 kb)
In the Matter of Amendments to Iowa Court Rules Regulating Student Practice (March 21, 2014)
Order (29 kb)
Rule 31.15 Student Practice Rule (152 kb)
OPR Memo Re: Amendment of Student Practice Rule (65 kb)
In the Matter of Amendments to Iowa Court Rules Regulating Continuing Legal Education (March 21, 2014)
Order (28 kb)
Chapters 41 and 42 (176 kb)
OPR Memo Re: Distance Education Changes as Adopted (65 kb)
In the Matter of Adoption of New Chapter 17 Forms for Applications to Modify Child Support in the Iowa Court Rules (March 6, 2014)
Order (406 kb)
Rule (127 kb)
Forms (1451 kb)
Guide (492 kb)
In the Matter of Chapter 17 of the Iowa Court Rules and Adoption of New Forms for Dissolutions of Marriage with Children (December 19, 2013)
Order (79 kb)
Divorce Forms for Self Represented Litigants With Minor Children (4394 kb)
Guide to Representing Yourself in an Iowa Divorce Case with Minor Children (543 kb)
Chapter 17 of the Iowa Court Rules (153 kb)
In the Matter of Amendments to Division III of the Court Rules Regarding the Client Security Trust Fund (November 26, 2013)
Order (160 kb)
Office of Professional Regulation Memorandum (118 kb)
Chapter 39 and 40 (141 kb)
In the Matter of Adoption of New Forms for Dissolutions of Marriage with no Minor Children (November 6, 2013)
Order (60 kb)
Divorce Forms for Self Represented Litigants With No Minor Children (2415 kb)
Guide to Representing Yourself in an Iowa Divorce Case with no Minor Children (445 kb)
In the Matter of Interim Rules to Govern the use of the Electronic Document Management System (October 22, 2013)
Supervisory Order (66 kb)
Rules 16.302, 16.320, 16.701 (132 kb)
In the Matter of the New Rule of Juvenile Procedure (October 16, 2013)
Juvenile Procedure 8.36
Order (125 kb)
Rule 8.36 (253 kb)
Standards of Practice (309 kb)
In the Matter of Amendments to Iowa Court Rules Regulating Admission to the Bar (August 22, 2013)
Effective immediately
Order (25 kb)
Chapter 31, Admission to the Bar (214 kb)
In the Matter of Adoption of Clarifying Comments (June 13, 2013)
Iowa Rule of Professional Conduct 32:1.13
Effective immediately
Order (61 kb)
In the Matter of Iowa Court Rules New Chapter 26 (June 4, 2013)
Rules for Installment Payment Plans and Other Court Collection Activities
Effective July 1, 2013
Order (253 kb)
Chapter 26 (294 kb)
In the Matter of Amendments to Iowa Court Rules Chapter 9 (May 9, 2013)
Child Support Guidelines
Effective July 1, 2013
Order (69 kb)
Chapter 9, Child Support Guidelines (2035 kb)
Child Support Guidelines Review Committee Final Report (2595 kb)
In the Matter of Amendments to Rules of Appellate Procedure and Organization and Procedures of Appellate Courts in Chapters 6 and 21 of the Iowa Court Rules (March 5, 2013)
The Iowa Supreme Court has approved rules governing electronic appellate processes. The rules, to be contained in the Chapter 16 court rules pertaining to EDMS, are prospective only. The court will announce an effective date for the rules and for implementation of electronic filing in the appellate courts at a later date.
Order (63 kb)
In the Matter of Amendments to Rules of Appellate Procedure and Organization and Procedures of Appellate Courts in Chapters 6 and 21 of the Iowa Court Rules (March 5, 2013)
The Iowa Supreme Court has amended the rules of appellate procedure contained in chapter 6 of the Iowa Court Rules and has rescinded and rewritten the rules governing the organization and procedures of appellate courts contained in Chapter 21 of the Iowa Court Rules.
Effective May 3, 2013
Order (74 kb)
Chapter 6 and Chapter 21 (116 kb)
In the Matter of Adoption of an Emeritus Pro Bono Practice Rule (March 1, 2013)
The Iowa Supreme Court has adopted an emeritus pro bono practice rule (Iowa Court Rule 31.19) that encourages retired or retiring Iowa attorneys, including attorneys licensed in other states, to provide volunteer legal services on behalf of legal aid organizations serving low income persons in Iowa.
Effective immediately
Order and Rule Amendments (323 kb)
In the Matter of New Rule of Civil Procedure (December 6, 2012)
The Iowa Supreme Court has approved the addition of rule 1.1702 to the Iowa Rules of Civil Procedure providing a uniform process for interstate depositions and discovery.
Supervisory Order (157 kb)
In the Matter of Amendments to the Iowa Court Rules (November 8, 2012)
Forms Regarding Appointment of Counsel
Temporarily adopting the attached forms, effective immediately. Forms permanently take effect January 7, 2013.
Supervisory Order and Forms Regarding Appointment of Counsel (294 kb)
In the Matter of Iowa Court Rule 31.16 (Sept. 13, 2012)
Registration of House Counsel
Effective immediately
Order (49 kb)
Chapter 31 (272 kb)
In the Matter of Standard Forms of Pleadings for Small Claims Actions (Sept. 13, 2012)
Chapter 3 of the Iowa Court Rules -- Form 3.27:Verification of Account
Effective immediately
Order (90 kb)
Chapter 3, Form 3.27 (45 kb)
In the Matter of Amendments to the Iowa Court Rules Governing Lawyer Advertising (August 28, 2012)
Effective January 1, 2013
Order and Chapter 32 (1114 kb)
In the Matter of Amendments to Iowa Court Rules 35.17 and 42.1 (August 24, 2012)
Effective immediately
Order, Rule 35.17 and 42.1 (66 kb)
In the Matter of Amendment of Iowa Court Rule 35.1 (August 24, 2012)
Effective immediately
Order, Rule 35.1 (56 kb)
In the Matter of Amendments to Iowa Court Rules Regulating Admission to the Bar (July 13, 2012)
Effective immediately
Order, Rule 31.11(3), and OPR change to rule 31.12 (119 kb)
In the Matter of Chapter 13 of the Iowa Court Rules (July 5, 2012)
Supervisory Order, Chapter 13 (516 kb)
In the Matter of Chapter 13 of the Iowa Court Rules (June 29, 2012)
Order, Chapter 13 and Forms (1418 kb)
In the Matter of Amendments to Rules of Appellate Procedure (May 21, 2012)
6.1005 Regarding Frivolous Appeals and Withdrawal of Counsel (Including Related Changes to Other Rules)
Effective immediately
Order (147 kb)
Rule 6.1005 (194 kb)
In the Matter of Standard Forms of Pleadings for Small Claims Actions (May 7, 2012)
Chapter 3 of the Iowa Court Rules is rescinded effective July 1, 2012, and revised Chapter 3 is adopted. Until July 1, 2012, parties may use either the current pleadings forms or the new pleadings forms.
Order (129 kb)
Chapter 3 -- Small Claims forms (711 kb)
In the Matter of Amendments to Iowa Court Rules Regulating the Practice of Law (May 2, 2012)
Amendments concerning the attorney disciplinary process, client trust account reconciliation and record retention procedures, continuing legal education, and the bar exam.
Amended effective immediately
Nunc Pro Tunc (59 kb)
OPR Rules Revisions (Strikethrough version) (4618 kb)
OPR Rules Revisions (Final version) (396 kb)
In the Matter of Amendments to Iowa Court Rule 32:7.4 (March 12, 2012)
The Court adds Veterans Law to the list of fields of practice and specialization.
Order (80 kb)
Iowa Courts Rules
The Chief Justice has signed a supplemental order specifying the effective date of the amendment to Rule 41.3(2)
Supplemental Order (35 kb)
Iowa Court Rules (February 20, 2012)
Amendments concerning the attorney disciplinary process, client trust account reconciliation and record retention procedures, continuing legal education, and the bar exam.
Amended effective immediately
Order (183 kb)
Amendments (10043 kb)
Summary of Amendments (87 kb)

Des Moines, December 3, 2014– The Iowa Supreme Court Lawyer Trust Account Commission is accepting applications for grants under the Interest on Lawyer Trust Account (IOLTA) program for the grant period that begins July 1, 2015. IOLTA program grants are awarded to public purpose projects that provide legal services to low-income persons in civil cases, law-related education, and other programs that improve the administration of justice in Iowa.

Under the provisions of chapter 44 of the Iowa Court Rules, applicants must file one copy of their application in paper form, and one copy of their application in electronic form. Organizations may obtain a copy of the rules and grant application forms (paper and electronic) by contacting the Lawyer Trust Account Commission, Judicial Branch Building, 1111 East Court Avenue, Des Moines, Iowa 50319, by calling (515) 725-8029, or by electronic mail to iolta@iowacourts.gov. Application forms also may be downloaded from the Commission's web page on the Judicial Branch web site at:

http://www.iowacourts.gov/For_Attorneys/Professional_Regulation/IOLTA/

The Commission must receive completed grant applications no later than 4:30 p.m., Friday, March 6, 2015. The Commission will then review the applications and seek approval from the Iowa Supreme Court for awarding the grants. Grant recipients will be announced in late May or early June of 2015.

The Iowa Supreme Court created the Lawyer Trust Account Commission to provide legal services to low-income persons in civil cases using the interest from lawyers' pooled trust accounts. The lawyers' pooled trust accounts hold clients' funds that are so small in amount or held for such a brief period that it is not possible for the funds to economically benefit the individual clients. Previously, attorneys' trust accounts earned no interest. The first grants awarded under the IOLTA program were made in June, 1986. To date, the Commission has awarded more than $24 million in grants.

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