## Facts

- John A. Klinge and Kevin Bentien, both Iowa farmers, entered an oral arrangement under which Bentien placed feeder pigs on Klinge’s farm for care and feeding until market weight.
- Klinge sued Bentien in small claims court for $3,000, alleging underpayment.
- Bentien counterclaimed for $5,000, alleging Klinge’s negligence caused the death of approximately 100 pigs.
- Neither party had counsel in small claims court, and neither requested farm mediation or obtained a mediation release under Iowa Code chapter 654B before litigating.
- The small claims court entered judgment for Klinge for $3,000 and for Bentien for $5,000.
- Klinge appealed only the $5,000 judgment to the district court; Bentien did not appeal the $3,000 judgment.
- The district court concluded the evidence was insufficient to support either claim, reversed the $5,000 judgment, but left the $3,000 judgment intact because Bentien had not appealed.
- After the district court ruling, Bentien obtained counsel, who asserted the courts lacked authority because chapter 654B mediation had not occurred and asked for dismissal from the outset; the district court declined to act.
- Bentien sought discretionary review in the Iowa Supreme Court, challenging the continued validity of the judgments based on the mediation requirement.

## Issues

1. Whether Iowa Code chapter 654B’s farm-mediation process is a jurisdictional prerequisite that deprives courts of authority over covered farm disputes absent mediation (or a mediation release).
2. Whether the small claims and district court judgments were void because neither party initiated chapter 654B mediation before litigating.

## Decision

- The Iowa Supreme Court held chapter 654B mediation is mandatory and jurisdictional for covered farm disputes.
- Because neither party requested mediation or obtained a mediation release, the small claims court and the district court lacked subject-matter jurisdiction/authority to adjudicate either the claim or the counterclaim.
- The Court reversed and remanded with directions to dismiss both parties’ claims without prejudice, vacating the judgments.

## Legal Principles

- For disputes within Iowa Code chapter 654B, requesting farm mediation and obtaining the required mediation release are conditions precedent to suit.
- Noncompliance with chapter 654B is a jurisdictional defect that cannot be cured by participation, consent, waiver, or failure to object.
- Judgments entered without satisfying the chapter 654B mediation requirement are void and must be vacated.
- Dismissal for failure to satisfy chapter 654B is without prejudice, permitting refiling after statutory mediation requirements are met.

## Conclusion

The Iowa Supreme Court required dismissal of both the small-claims action and counterclaim because mandatory farm mediation under Iowa Code chapter 654B is a jurisdictional prerequisite; absent mediation or a release, courts lack authority and resulting judgments are void.


Klinge v. Bentien, 725 N.W.2d 13 (Iowa 2006)