## Facts

- Clarence and Herthel Uhl owned a farm near Sioux City, Iowa.
- In 1972, the City of Sioux City and the Iowa State Highway Commission entered a pre-design agreement for an interstate bypass connecting U.S. Highway 20 and Interstate 29.
- The planned bypass would split the Uhls’ farm and required acquisition of some property interests, including access-related interests.
- The Uhls alleged the project damaged or effectively took property interests without formal condemnation or just compensation.
- The Uhls sued the City alleging inverse condemnation and related theories, including breach of obligations they attributed to the City under the project agreement.
- The district court granted judgment for the City, concluding the claims were barred by limitations and that the City was not legally responsible under the asserted theories.

## Issues

1. When did the Uhls’ causes of action accrue for limitations purposes on claims arising from the bypass’s alleged taking or damaging of their property interests?
2. Whether the City could be held liable for a compensable taking or damages associated with a state highway bypass under the 1972 project agreement and Iowa law.

## Decision

- The Iowa Court of Appeals affirmed judgment for the City.
- The court held the claims were time-barred because accrual occurred when the alleged wrong was complete and the injury was known or reasonably knowable, not when later effects were felt.
- The court rejected a “continuing violation” theory where later impacts were treated as consequences of an earlier completed act.
- The court held the City was not the proper liable entity for takings-related claims tied to the design, construction, or operation of the interstate bypass; responsibility rested with the State as the highway authority.

## Legal Principles

- A claim accrues, and the statute of limitations begins to run, when the alleged wrong is complete and the plaintiff knew or reasonably should have known of the injury giving rise to the right to sue.
- Continuing adverse effects from a completed public project do not, by themselves, restart limitations periods.
- Liability under intergovernmental project agreements depends on the agreement’s allocation of duties; a city’s commitment to acquire rights-of-way does not, without clear language, make it responsible for all later takings-related consequences of a state-constructed interstate project.
- For takings or damages resulting from state highway construction, the State is generally the proper defendant absent a statute or agreement shifting that liability to a municipality.

## Conclusion

The court affirmed dismissal of the Uhls’ action because the claims accrued earlier than suit was filed and because the City’s agreement-related duties did not make it responsible for takings allegedly caused by a state-controlled interstate bypass project.


Uhl v. City of Sioux City, 490 N.W.2d 69 (Iowa Ct. App. 1992)