## Facts

- Mike Mart leased a 240-acre Iowa farm from his father, George Mart, under a written 20-year farm lease.
- The lease required Mike to pay George $85 per tillable acre each year.
- Under federal “Swampbuster” provisions of the Food Security Act of 1985, 8.7 acres of the farm were designated wetlands/converted wetlands subject to restrictions on planting commodity crops.
- After George died, ownership of the farm passed equally to four siblings: Mike Mart and his siblings Dennis, Thomas, and Cheryl Mart.
- About ten years into the lease, Mike planted corn on the 8.7 acres despite the Swampbuster designation.
- Because of Mike’s planting, the federal government penalized the farm’s owners by denying approximately $152,000 in federal farm-program benefits.
- Dennis, Thomas, and Cheryl appealed administratively, asserting they were unaware of Mike’s noncompliance; they prevailed and ultimately received the denied benefits.
- The following year, Mike restored the 8.7 acres to wetlands and stopped cropping the area.
- Dennis, Thomas, and Cheryl sought to cancel the lease and then filed a forcible entry and detainer (FED) action to remove Mike from possession.
- The trial court denied the FED petition, concluding the owners were not entitled to dispossess Mike; the siblings appealed.

## Issues

1. Did Mike’s one-season planting of corn on federally protected wetland acreage constitute a material breach of the farm lease that allowed the co-owner siblings to terminate the lease and recover possession through forcible entry and detainer?
2. If there was a lease breach, could the owners obtain FED relief when Mike restored the wetland and the owners recovered the withheld federal benefits, leaving no net monetary loss?

## Decision

- The Iowa Court of Appeals affirmed the denial of the owners’ FED petition.
- The court treated FED as a narrow, summary remedy focused on the present right to possession, not a vehicle to impose forfeiture for a past violation that has been remedied.
- Given Mike’s restoration of the wetland acreage and the owners’ recovery of the federal benefits, the court concluded the owners had not shown a basis for dispossession through FED.

## Legal Principles

- Forcible entry and detainer is a summary statutory procedure to decide the right to immediate possession; it is not designed to fully litigate contract disputes or impose punitive forfeitures.
- Lease forfeiture is disfavored; courts are reluctant to terminate a long-term lease and order eviction when the complained-of conduct has been corrected and the landlord cannot show continuing harm or uncompensated loss.
- A tenant’s duties under a farm lease may include compliance with conservation and environmental program requirements connected to the land.
- “Good husbandry” and similar farm-practice terms are fact-dependent and measured against what a reasonably prudent farmer would do under the circumstances, including stewardship and conservation considerations.

## Conclusion

In *Mart v. Mart*, the Iowa Court of Appeals held that the co-owner siblings were not entitled to remove the tenant through forcible entry and detainer based on a single-season Swampbuster wetland violation where the tenant later restored the wetlands and the owners ultimately recovered the withheld federal benefits, leaving no net damages and no ongoing basis for summary dispossession.


Mart v. Mart, 824 N.W.2d 535 (2012)