## Facts

- Medical Associates Clinic, P.C. owned an office building and an adjacent undeveloped open field near a residential neighborhood.
- Monty Alexander entered the open field at night, without the clinic’s knowledge or permission, to retrieve his sister’s dog.
- In the dark, Alexander fell into a ditch on the property and injured his knee.
- Alexander sued the clinic alleging negligent maintenance of the property.
- The clinic asserted Alexander was a trespasser and that its only duty was to avoid willful and wanton injury.
- The district court granted summary judgment for the clinic, concluding Alexander was a trespasser as a matter of law and the record showed no willful or wanton conduct.
- Alexander appealed, urging adoption of a general negligence standard for landowner liability to trespassers.

## Issues

1. Whether Iowa should replace the common-law rule limiting a landowner’s duty to trespassers (avoid willful and wanton injury) with a general negligence standard.
2. Whether, under the willful-and-wanton standard, the evidence generated a triable issue that the clinic breached its duty to Alexander.

## Decision

- The Supreme Court of Iowa affirmed summary judgment for the clinic.
- The court declined to abolish the common-law trespasser rule and refused to adopt a general negligence standard for trespassers.
- The court agreed Alexander was a trespasser as a matter of law because he entered the property without permission or invitation.
- The court found no evidence from which a reasonable factfinder could infer willful or wanton conduct by the clinic.
- Because the clinic owed only the limited duty applicable to trespassers and the record did not support breach of that duty, the clinic was entitled to judgment as a matter of law.

## Legal Principles

- In Iowa, a landowner’s duty to a trespasser is limited to refraining from willful and wanton injury; no general duty of reasonable care is owed to undiscovered or uninvited entrants.
- Entrant classification remains controlling in Iowa; courts will not impose ordinary negligence liability to trespassers absent willful or wanton conduct.
- Summary judgment is proper where material facts are undisputed, the plaintiff’s legal status fixes a limited duty, and the record lacks evidence sufficient to support a finding of breach under the applicable standard.

## Conclusion

The Iowa Supreme Court reaffirmed that landowners generally owe trespassers only a duty to avoid willful and wanton injury, rejected a shift to a unitary negligence standard, and held that an undiscovered ditch in an undeveloped field—without proof of willful or wanton conduct—could not support liability.


Alexander v. Med. Assocs. Clinic, P.C., 646 N.W.2d 74 (Iowa 2002)