In re Marriage of Sprague

CourtCourt of Appeals of Iowa
DecidedAugust 6, 2025
Docket24-1015
StatusPublished

This text of In re Marriage of Sprague (In re Marriage of Sprague) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Marriage of Sprague, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1015 Filed August 6, 2025

IN RE THE MARRIAGE OF JOHNATHON SPRAGUE AND LANORA SPRAGUE

Upon the Petition of JOHNATHON SPRAGUE, Petitioner-Appellant,

And Concerning LANORA SPRAGUE, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, John Telleen, Judge.

A father appeals the district court’s order requiring him to sign a settlement

agreement in this dissolution-of-marriage modification action. REVERSED AND

REMANDED.

Peter G. Gierut of Gallagher, Millage & Gallagher, P.L.C., Bettendorf, for

appellant.

Jennie L. Clausen of H.J. Dane Law Office, Davenport, for appellee.

Considered without oral argument by Ahlers, P.J., and Badding and

Buller, JJ. Telleen, S.J., takes no part. 2

AHLERS, Presiding Judge.

The marriage of Johnathon (John) and Lanora Sprague was dissolved in

June 2017. The parties were granted joint legal custody and joint physical care of

their minor children.

Lanora later filed a petition to modify the parties’ legal-custody and physical-

care arrangement. On the day of trial of the modification action, the parties

believed they reached a verbal settlement agreement.1 However, the agreement

was not reduced to writing or read into the record. The parties intended to reduce

the agreement to writing on a later date.

Unfortunately, reaching agreement on the details of the settlement proved

elusive. While the parties agreed on the primary terms, they disagreed over details

on a number of issues, including transportation to school and the children’s

participation in extracurricular activities. John maintains that these issues were

discussed between and agreed to by the parties during their settlement conference

on the morning of trial. Lanora asserts that the details about transportation and

participation in extracurricular activities that John maintains were agreed to were

either not discussed or not agreed to when the parties agreed they had reached a

settlement. Lanora contends John has added these details after the fact due to

buyer’s remorse.

After the parties exchanged drafts of a proposed settlement agreement and

1 Part of the agreement was that they could not reach a consensus on where the

children should attend school, so they agreed to submit that issue to the district court as a contested matter that day. They did so, and the district court issued a ruling deciding where the children would attend school. Neither party disputes that ruling, so it is not an issue on appeal. 3

were unable to reach a final consensus on the details, Lanora filed a motion to

enforce the settlement, and John resisted the motion. The motion was set for

hearing before the same district court judge who was scheduled to preside at the

modification trial and who was present when the parties informed the court that a

settlement agreement had been reached the day of trial.

The court heard arguments on the motion and John’s resistance. The

hearing was not reported. Following the hearing, the court ordered both parties to

sign and execute the written agreement drafted by Lanora—excluding John’s

proposed additions—finding that it reflected the terms to which the parties agreed

on the day of trial. John appeals. Lanora stands by the district court’s order and

requests us to order John to pay her appellate attorney fees.

Courts generally have authority to enforce settlement agreements made in

a pending case. Wende v. Orv Rocker Ford Lincoln Mercury, Inc., 530 N.W.2d 92,

95 (Iowa Ct. App. 1995). We review challenges to the enforcement of a settlement

agreement for correction of errors at law. Est. of Cox v. Dunakey & Klatt, P.C.,

893 N.W.2d 295, 302 (Iowa 2017).

A court’s authority to enforce a settlement agreement in a pending case is

exercised in two ways. Wende, 530 N.W.2d at 94. If material facts are not

disputed, the court can enforce the agreement by applying summary judgment

standards. Id. If the material facts are disputed, the issue must be resolved by the

fact finder by the parties presenting evidence as an additional claim in the original

action in a separate hearing. Id.2

2 As we noted in Wende, “[u]nder either method, the issue is most appropriately

raised by first amending the pleadings to assert settlement as a claim in the 4

Here, we are dealing with the first way. Lanora’s motion asking the court to

enforce the claimed settlement agreement alleged “[t]here is no dispute that the

terms set forth in the [stipulation attached to the motion]” were “the terms that were

agreed upon by the parties.” John’s resistance disputed Lanora’s assertion that

the terms set forth in the stipulation attached to her motion were agreed to and

asserted that the agreement that was reached included different terms—those

asserted in his resistance. After an unreported hearing, the district court granted

Lanora’s motion with an order stating that the court “has reviewed the Motion to

Enforce Settlement and the Resistance and has considered the arguments of

counsel.” The order also referenced the court’s recollection of events at the earlier

settlement conference before concluding the parties “reached a settlement” and

the stipulation attached to Lanora’s motion “is an accurate recitation of the parties’

settlement agreement.”

Both the parties’ filings with the district court and the court’s resolution of

Lanora’s motion are consistent with the procedures “applicable to motions for

summary judgment.” See id. (applying summary judgment standards when

material facts are not in dispute). Similarly, the parties’ positions on appeal are

consistent with summary judgment standards, as John contends the district court

erred in finding there was no material fact at issue, whereas Lanora argues the

lawsuit.” 530 N.W.2d at 94 n.1. “The issue may then be resolved by motion for summary judgment or at trial. Our rules of procedure do not provide for a motion to enforce a settlement agreement.” Id. Neither party, however, has argued that the issue could not be reached through Lanora’s motion. See Wright v. Scott, 410 N.W.2d 247, 248–49 (Iowa 1987) (declining to consider whether presenting the settlement enforcement issue to the district court through a motion was the correct procedure when neither party challenged addressing the issue by motion). 5

district court properly found there was no dispute over material facts. As such, we

apply summary judgment standards.3 See id. In doing so, because the hearing

on Lanora’s motion was not reported and neither party filed a motion pursuant to

Iowa Rule of Appellate Procedure 6.806 to complete the record, we do not

speculate about what took place at that hearing, and, to the extent either party

asks us to so speculate, we decline to do so. See In re Est. of Thacker, No. 23-

1828, 2025 WL 548035, at *1 (Iowa Ct. App. Feb. 19, 2025) (ruling on the merits

3 As previously noted, both Lanora’s motion and John’s resistance framed the

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Related

Wright v. Scott
410 N.W.2d 247 (Supreme Court of Iowa, 1987)
Wende v. Orv Rocker Ford Lincoln Mercury, Inc.
530 N.W.2d 92 (Court of Appeals of Iowa, 1995)
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696 N.W.2d 1 (Supreme Court of Iowa, 2005)
Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
Smith v. Iowa Board of Medical Examiners
729 N.W.2d 822 (Supreme Court of Iowa, 2007)
In the Interest of T.V.
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In Re the Marriage of Ricklefs
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Simon Estes v. Progressive Classic Insurance Company
809 N.W.2d 111 (Supreme Court of Iowa, 2012)
In re F.W.S.
698 N.W.2d 134 (Supreme Court of Iowa, 2005)

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